Dickerson v. United States

Facts

Dickerson was indicted for bank robbery, conspiracy to commit bank robbery, and using a firearm in the course of committing a crime of violence, all under Title 18 of the United States Code. Before trial, he moved to suppress a statement he had made at a Federal Bureau of Investigation field office. He argued that he had not received Miranda warnings before he was interrogated. The courts below agreed that he had not received them. In Miranda v. Arizona, decided in 1966, the Court had held that certain warnings must be given before a suspect's statement made during custodial interrogation could be admitted in evidence. Those four warnings tell the suspect that he has the right to remain silent, that anything he says can be used against him in court, that he has the right to the presence of an attorney, and that an attorney will be appointed if he cannot afford one. Two years after Miranda, Congress enacted 18 U.S.C. §3501. In prosecutions brought by the United States or the District of Columbia, that section makes a confession admissible if it is voluntarily given. It tells the trial judge to weigh all the circumstances, including whether the defendant was advised of his rights, and says no single factor need be conclusive. It does not require warnings. No party defended §3501 in the Supreme Court, so the Court invited Professor Paul Cassell to argue in support of the judgment below.

Issues

1. Did Congress have constitutional authority, through 18 U.S.C. §3501, to replace Miranda's warnings requirement with a rule that makes the admissibility of a confession turn only on whether it was voluntary?
2. Did Miranda announce a constitutional rule, or did it only exercise the Court's supervisory authority to regulate evidence in the federal courts when Congress had given no direction?
3. Should the Court overrule Miranda itself, which would let §3501 govern, or do the principles of stare decisis weigh against doing so?

Holding

Miranda announced a constitutional rule that Congress may not supersede legislatively, so §3501, which makes voluntariness alone the test, cannot stand. The Court declined to overrule Miranda, which with its progeny governs admissibility of statements made during custodial interrogation in both state and federal courts.