Tuesday, December 24, 2013

United States v. Mandujano case brief

United States v. Mandujano case brief summary
425 U.S. 564 (1976)

Petitioner, the United States, appealed a judgment of the United States Court of Appeals for the Fifth Circuit, which affirmed the grant of a motion filed by respondent, a grand jury witness, to suppress the false statements that the witness made before the grand jury, and which were the basis of his indictment for perjury in violation of 18 U.S.C.S. § 1623, because the witness did not receive Miranda warnings before testifying.

The grand jury witness was called to testify before the grand jury. He was informed that he had to answer all questions truthfully except those that he felt might incriminate him. He made false statements about his recent criminal activities, and was indicted pursuant to 18 U.S.C.S. § 1623 for making false statements to the grand jury. He then moved to suppress the statements on the ground that he did not receive full Miranda warnings before testifying. The district court granted the motion, which was affirmed on appeal.

  • On certiorari, the court held that the grand jury witness was not entitled to Miranda warnings because he was not a suspect in police custody. 
  • The court held that as a witness before a grand jury, he did not have Miranda rights. 
  • U.S.Constitutional Amendment V gave a witness a right to refuse to answer questions that would incriminate him, but it did not give him the right to commit perjury and then have his statements suppressed as incriminating.
The court reversed the judgment and remanded the case because the grand jury witness had an absolute duty to testify truthfully. He was not entitled to receive Miranda warnings prior to testifying before the grand jury. Although he could refuse to answer incriminating questions, if he chose to answer those questions falsely, he could be prosecuted for perjury and those statements could be used against him.

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