Case Title: County of Riverside v. McLaughlin 500, 1991
Fact Summary:
In August of 1987, McLaughlin made a complaint to the US District Court for the Central District of California. His complaint was that he was held in Riverside County Jail and did not receive a probable cause determination by a judge. McLaughlin made the request for a judicial determination for himself and others in the jail who experienced a warrantless arrest. Furthermore, his request included prompt probable cause, bail and arraignment hearings by a judge for defendants who have been arrested. McLaughlin extended his case to a class action suit. One year later, after three more plaintiffs joined the suit, the District Court approved the class action to apply to any Riverside County prisoners who are arrested without warrants and were denied prompt probable cause hearings.
Issue:
In the case of Riverside County v. McLaughlin, the Court must decide whether Riverside conducted a prompt probable cause hearing as defined by Gerstein. Under the case Gerstein v. Pugh, the Court had ruled that the Fourth Amendment right against unreasonable searches and seizures requires a judge to make a prompt determination of probable cause after a warrantless arrest is conducted.
Holding of the Court:
The Court found that Riverside County did not fulfill their obligation under Gerstein to give defendants a prompt judicial determination of probable cause within forty-eight hours of their arrest.
Majority Opinion:
The Court believes that Riverside County failed to give their defendants a prompt probable cause hearing within forty-eight hours of their arrest. Furthermore, under Gerstein, Riverside County did not act promptly to provide the defendants with a judicial determination of probable cause, bail, and arraignment hearings. If the Court is not able to conduct the probable cause hearing within forty-eight hours, they must show exigent circumstances. Moreover, extending the probable cause hearing longer than forty-eight hours cannot be justified because the defendant was arrested as the weekend approached.
Dissenting opinion:
There were a few dissenting opinions in the case of Riverside County v. McLaughlin. Justices Marshal, Stevens and Blackmun each dissented because they believed that a probable cause hearing meets the Gerstein requirement of being prompt only if it is done right after administrative steps of an arrest have been completed. Justice Scalia dissented for the reason that once the defendant was arrested and a neutral judge was available, the probable cause hearing should take place, which actually meant prompt. Furthermore, Scalia’s definition of prompt was to conduct the probable cause hearing within twenty-four hours of the arrest.
Case Title: The People of the State of Illinois v. Michael Glanton 33, 1975
Fact Summary:
Officer Bertucci testified that on April 16, 1969 he and Officer Nolan were investigating homicides near a Chicago alley by the railroad tracks. The officers found two dead people lying near the tracks. The officers then questioned people around the scene of the crime and were directed to John Payton who was the leader of the neighborhood youths. Payton then directed the officers to a man named Washington. Washington was taken to the police station for questioning, yet when he arrived he was arrested for murder. The police stalled Washington’s interrogation because they had received a tip about the location of one of the murder weapons. As the officers went to look for the gun, they saw the defendants Glanton and Johnson talking to some police officers. Bertucci decided to arrested Glanton and Johnson with securing a warrant and charged them with murder. The defendants then lead the officers to a garage where the officers found the weapons.
Issue:
The issue was whether it was legal for the officers to conduct warrantless arrests of the defendants without having any probable cause. One of the defendants, Washington argued that he was not informed of his rights when he gave a statement to the officer.
Holding of the Court:
The Court held that the warrantless arrests were legal because the officers had probable cause. The Court believes that the evidence against the defendants provided the officers with sufficient probable cause to arrest them.
Majority Opinion:
The Court found that the officers were acting in accordance with the law when they made warrantless arrests. The Court also found that the officers had enough probable cause to conduct the arrest. The defendant’s argument was that the officers arrested them when they were not doing anything illegal. However, the officers believed they had enough credible information that the defendants were involved in the crime that was being investigated. Therefore, the weapons that were acquired during the investigation are admissible in court. On Washington’s contention, the Court found that since an officer provided testimony that Washington had been informed of his rights many times, his statements were given voluntarily.
Dissenting opinion:
This case had no dissenting opinion. All of the judges agreed with the original opinion of the trial court.
Case Title: Miranda v. Arizona 384, 1966
Fact Summary:
The Supreme Court decided on four cases together in which the defendants were not informed of their rights. The first defendant was Miranda who was not informed of his Fifth Amendment right, which protects against self-incrimination. Miranda later signed a confession, which stated that he was informed of his rights. The second defendant was Vignera who told the officer that he committed a robbery. The third defendant was Westover who was interrogated for a very long time and then the FBI took the case and got a confession out of him. This defendant did not waive his Fifth Amendment right either. The last defendant was Stewart who was arrested and detained for five days and questioned nine different times. Stewart finally confessed, but he was not told of his right to remain silent or right to counsel. These four cases showed that police had interrogated the defendants without informing them of their right against self-incrimination and right to counsel.
Issue:
The issue was whether a defendant’s Fifth Amendment right against self-incrimination is violated if they are interrogated without being informed of their right to remain silent.
Holding of the Court:
The Court found that police must advise the arrestee of their Fifth Amendment right to remain silent and right to counsel. If police neglects to inform the defendant of their rights, any confessions will be inadmissible to use in court.
Majority Opinion:
The Court believes that police are required to inform the person they arrest that he has the right to remain silent and to have his counsel with him during an interrogation. The police should give these “Miranda warnings” before conducting an interrogation of the defendant. Furthermore, the prosecuting attorneys are not allowed to use any confessions or statements from the defendant until the defendant is aware of his Fifth Amendment rights. Once the defendant acknowledges that he understands his rights, he may choose to remain silent or waive his rights and make statements or a confession. The Court found the Miranda warnings to be essential to the proper functioning of the justice system because it deals with the rights of a person and they should know that statements they make would be used against them in court.
Dissenting opinion:
Justice Harlan dissented on the grounds that the Fifth Amendment contains due process clause such as the right to counsel, which should apply to interrogations of defendants. However, Justice Harlan believes that the Fifth Amendment is not meant to exclude all means of self-incrimination. Justice White dissented that there is no reason that the Fifth Amendment should create an additional law known as the Miranda Warning.