Miranda v. Arizona

Audience

Miranda v. Arizona speaks to many audiences. First, the justices address one another. In the majority opinion, Warren often writes to answer or head off objections drawn by the dissenters, just as those objections speak directly to the Court's holding. Warren also replies to concerns of Justice William Brennan, who joined him in the majority, in issuing the invitation to Congress and the states to continue their efforts to develop criminal law. Those legislative bodies are a second audience addressed by the document. A third audience, also governmental, is larger: police departments and their personnel throughout the nation, to whose daily actions the Miranda rules apply directly. Lower courts, a fourth audience, are expected to apply the findings of Miranda going forward.

A fifth audience is society at large. The legal scholar Morton Horwitz has noted that the Warren Court “regularly handed down opinions that have transformed American constitutional doctrine and, in turn, profoundly affected American society” (p. 3). Much of the majority opinion is written in a style that is easily accessible to a nonlegal audience; Warren often wrote this way. The four cases' defendants, who won reversals of their convictions, constitute a sixth audience. Ernesto Miranda, in particular, was granted a retrial in Arizona, at which his confession was inadmissible. Nevertheless, the state won convictions again, based on new evidence: Miranda's common-law wife testified that while he was in jail after confessing to the police, Miranda confessed to her that he committed the kidnapping and rape. Against a number of objections, that evidence was admitted, and Miranda was found guilty of the two crimes. The Arizona Supreme Court turned down his subsequent request for appeal.