Pennsylvania v. Muniz, 496 U.S. 582 (1990)

Facts

Muniz was seen in a car on the side of the road and when the officer stopped to see if he needed assistance, Muniz showed signs of inebriation.  After telling him to stay and sober up, Muniz drove off.  The officer then conducted sobriety tests and took him to the police station.  While at the station, Muniz was asked for biographical information and “do you know what the date was of your sixth birthday?”  Muniz said he did not know.

Procedural History

Muniz moved for a new trial because the court should have suppressed his statements and the booking center videotape.  The trial court denied the motion.  The Superior Court of Pennsylvania reversed, finding that when the physical nature of the tests yield testimonial statements, the Miranda protections are invoked.

Issue(s)

Did the Superior Court err in finding that all of Muniz’ statements should have been suppressed?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that in order to be testimonial, an accused’s communication must itself, explicitly or implicitly, relate a factual assertion or disclose information.  Testimonial evidence must encompass all responses that could place a suspect in a “cruel trilemma.”  The question regarding the sixth birthday required a testimonial response and should have been suppressed.  The biographical questions, however, were found to be routine booking questions and thus should not have been suppressed.

Judgment/Outcome

The Court vacated the judgment of the Superior Court.