Sunday, November 3, 2013

Rhode Island v. Innis case brief

Rhode Island v. Innis case brief summary
446 U.S. 291 (1980)

CASE SYNOPSIS
Petitioner, State of Rhode Island, appealed the judgment of the Supreme Court of Rhode Island, which set aside respondent's conviction for the kidnapping, robbery, and murder of a taxicab driver. The state supreme court found that respondent had been subjected to subtle coercion that was the equivalent of interrogation after respondent invoked his Miranda right to counsel.

CASE FACTS
Respondent was convicted of the kidnapping, robbery, and murder of a taxicab driver after the trial court denied respondent's motion to suppress the weapon and statements made by respondent to the police about the weapon. The state supreme court set aside respondent's conviction, finding that respondent had been subjected to subtle coercion that was the equivalent of interrogation after respondent invoked his Miranda right to counsel.

DISCUSSION
  • On appeal, the court vacated the judgment of the state supreme court. 
  • The court held that the Miranda safeguards came into play whenever a person in custody was subjected to either express questioning or its functional equivalent. 
  • The court held that the term "interrogation" under Miranda referred not only to express questioning, but also to any words or actions on the part of the police that the police should know were reasonably likely to elicit an incriminating response from a suspect. 
  • The court held that respondent was not interrogated within the meaning of Miranda when the police officers voiced safety concerns about children finding the weapon from the crime and respondent interrupted them to say he would show them where the gun was located.

CONCLUSION
The court vacated the judgment of the state supreme court that had set aside respondent's conviction for kidnapping, robbery, and murder. The court held that petitioner had not established that respondent's incriminating response was the product of words or actions on the part of the police that they should have known were reasonably likely to elicit an incriminating response.



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

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