Dickerson v. United States, 530 U.S. 428 (2000)

Facts

Dickerson was indicted for bank robbery, conspiracy to commit, and use of a firearm.

Procedural History

Dickerson moved to suppress a statement he made at an FBI field office because he had not been given his Miranda warnings.  The District Court granted the suppression.  The Appellate Court reversed, finding that §3501, which looks at whether statements were voluntary, was satisfied and because Miranda was not a constitutional holding, §3501 supersedes Miranda.

Issue(s)

Did the Appellate Court err in finding that Miranda was not a constitutional holding?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that Congress retains the ultimate authority to modify or set aside judicially created rules of evidence or procedure but Congress may not legislatively supersede decisions interpreting and applying the Constitution.  Miranda is replete with statements indicating that the majority thought it was announcing a constitutional rule.  The Court also found that it would not overrule Miranda because of stare decisis.  In sum, Miranda announced a constitutional rule which Congress may not supersede legislatively.

Judgment/Outcome

The Court reversed the judgment of the Court of Appeals.