| Venue: | SCOTUS |
| Facts: | Armed robbery of a bank. Dickerson isn't mirandized before he is interrogated. |
| Posture: | Motion to suppress is granted, and the government appeals. Reversed on the basis that 18 USC § 3501 makes this testimony admissible. Appealed. |
| Issue: | Was Miranda a constitutional decision, and therefore not one subject to "overruling" by statute? |
| Holding: | Yes, reversed. |
| Rule: | Only SCOTUS can overrule constitutional decisions. |
| Reasoning: | § 3501 clearly conflicts with Miranda, because it says that
voluntariness is the standard for admissibility. That's actually
what the standard was before Miranda, and in that
case, we were concerned about the efficacy of modern interrogation
techniques, and decided that constitutional rights needed additional
safeguards.
In enacting § 3501, congress is replacing our judgment with its own, but we are the final interpreters of the constitution. No way we're overruling Miranda: it's too firmly engrained. And it did announce a constitutional rule. So § 3501 is invalid. |
| Dicta: | Scalia, dissenting: we all want to prevent compelled confessions, but here the court is literally expanding the constitution, which is scary and anti-democratic. |