Saturday, November 2, 2013

Dickerson v. United States case brief

Dickerson v. United States case brief summary
530 U.S. 428 (2000)

Petitioner appealed from the judgment of the United States Court of Appeals for the Fourth Circuit, which reversed the grant of his motion to suppress his custodial statement, finding that 18 U.S.C.S. § 3501 had been satisfied.

Petitioner was indicted for bank robbery, conspiracy to commit bank robbery, and using a firearm in the course of committing a crime of violence. Before trial, petitioner moved to suppress a statement he had made at a Federal Bureau of Investigation field office, on the grounds that he had not received "Miranda warnings" before being interrogated.

The district court granted his motion to suppress. The court of appeals reversed the suppression order, holding that 18 U.S.C.S. § 3501, which made admissibility turn solely on whether the statement was made voluntarily, had been satisfied.

  • On appeal, the court reversed, finding that Miranda was a constitutional decision of the court, and therefore could not be in effect overruled by an Act of Congress. 
  • Further, following the principles of stare decisis, the court declined to overrule Miranda itself. 
  • The court held that Miranda and its progeny governed the admissibility of statements made during custodial interrogation in both state and federal courts.


Judgment reversed; Miranda announced a constitutional rule that Congress could not supersede legislatively, and following the rule of stare decisis, the court declined to overrule Miranda itself.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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