Rhode Island v. Innis, 446 U.S. 291 (1980)

Facts

A taxi driver had been murdered and police were informed another driver had been held up.  Police responded and found Innis, who was arrested and advised of his Miranda rights.  Innis was subsequently advised numerous times and invoked his right to counsel.  While en route to the police station, two officers were conversing about their concern for disabled children finding the shotgun.  Innis then exclaimed he would lead the police to the shotgun.

Procedural History

Innis moved to suppress the shotgun and his statements.  The trial court denied the motion, finding Innis’ utterance was a waiver.  The Rhode Island Supreme Court reversed, finding that the officers had interrogated Innis after he invoked his right to counsel.

Issue(s)

Did the Rhode Island Supreme Court err in finding that Innis had been interrogated while officers in the front seat were talking about their concerns for children with disabilities discovering the shotgun?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that interrogation refers not only to express questioning but also words or actions that the police should know are reasonably likely to elicit an incriminating response.  The conversation in the present case was nothing more than a dialogue between the officers to which no response from Innis was invited.  It cannot be said that the officers should have known their conversation was likely to elicit an incriminating response.

Judgment/Outcome

The Court vacated the judgment of the Rhode Island Supreme Court and reversed.