MIRANDA

Yarborough v. Alvarado, 541 U.S. __ (2004)—A suspect’s age is not a factor in determining whether he or she was “in custody” under Miranda. The Ninth Circuit Court of Appeals had held that the standard for custody under Miranda—whether a “reasonable person” would believe he or she was not free to leave—should be modified to a “reasonable juvenile person” when the suspect being questioned was under 18. The Supreme Court reversed, holding that there are “important conceptual differences” between the “in custody” determination under Miranda and other legal tests which take into account the suspect’s age. The Supreme Court held the “in custody” test under Miranda is an objective test under which the suspect’s characteristics, including age, are irrelevant. As a result, the Court held, the same standard applies to questioning of juveniles as to questioning of adults. The Supreme Court’s decision was 5-4, with Justice O’Connor filing a brief concurring opinion stating that “there may be cases in which a suspect’s age will be relevant to the Miranda custody inquiry,” but not specifying what those cases might be. She agreed with the majority that with the 17½-year-old suspect in this case, the custody determination should not consider his age.
http://supct.law.cornell.edu/supct/html/02-1684.ZS.html

Missouri v. Seibert, 542 U.S. ___ (June 28, 2004)—Incriminating statements obtained by using the so-called “question first” interrogation tactic are inadmissible as a violation of Miranda. In that technique police purposely question suspects without Miranda warnings, then only after obtaining incriminating statements, give the warnings and have the suspect repeat the statements. The Court held that procedure to be an unconstitutional evasion of the Miranda protections.
http://supct.law.cornell.edu/supct/html/02-1371.ZS.html

U.S. v. Patane, 542 U.S. ___ (June 28, 2004)—The “fruit of the poisonous tree” doctrine does not apply to physical evidence obtained as a result of an interrogation which violates Miranda. During questioning without the Miranda warnings, Defendant told police where they would find his illegal gun. Although the government conceded Defendant’s statements were inadmissible, the Court held that the gun itself, which was recovered as a result of the inadmissible statement, was admissible at Defendant’s trial.
http://supct.law.cornell.edu/supct/html/02-1183.ZS.html

SEARCH AND SEIZURE

Hiibel v. Sixth Judicial Court, 542 U.S. ___ (June 21, 2004)—Neither the Fourth nor Fifth Amendment prohibits prosecution under a state “stop and identify” statute. The Nevada statute in question required a person to “identify himself” under certain circumstances, but did not compel answer to any further inquiry. Defendant refused to provide officer with his name upon request, and was arrested. The Court held that the statutory identification requirement did not violate any provision of the U.S. Constitution.
http://supct.law.cornell.edu/supct/html/03-5554.ZS.html

Groh v. Ramirez, 540 U.S. ___ (Feb. 24, 2004)—A search warrant which fails to describe the things to be seized is so obviously deficient as to render a search based on the warrant presumptively unreasonable.
http://supct.law.cornell.edu/supct/html/02-811.ZS.html

Illinois v. Lidster, 540 U.S. ___ (Jan. 13, 2004)—Police roadblock checkpoints set up to ask motorists for information about a crime occurring several days before did not require individualized suspicion for traffic stops. Hence, the Fourth Amendment did not affect evidence of Defendant’s DWI discovered during the stop.
http://supct.law.cornell.edu/supct/html/02-1060.ZS.html

Thornton v. United States, 541 U.S. ___ (May 24, 2004)—The rule permitting searches of the passenger compartment of an automobile incident to the arrest of the occupant of the auto applies even if the occupant exits the vehicle prior to the arrest.
http://supct.law.cornell.edu/supct/html/03-5165.ZS.html

United States v. Banks, 540 U.S. ___ (Dec. 2, 2003)—The 15 to 20 seconds which officers waited after announcing their presence with a search warrant before their forced entry into the Defendant’s home was reasonable in light of the exigent circumstance created by their “knock and announce”; i.e. that Defendant might destroy the cocaine for which the warrant authorized a search.
http://supct.law.cornell.edu/supct/html/02-473.ZS.html

Banks v. Dretke, 540 U.S. ___ (Feb. 24, 2004)—The Court found that the prosecution in a capital case had willfully suppressed evidence which might have impeached a key witness and allowed testimony it knew was false to stand uncorrected in the record. As a result, the Court held, the prosecution’s omissions to disclose potentially exculpatory evidence constituted a Brady violation.
http://supct.law.cornell.edu/supct/html/02-8286.ZS.html

Beard v. Banks, 542 U.S. ___ (June 24, 2004)—The Court’s holdings in Mills v. Maryland, 486 U.S. 367 (1988), and McKoy v. North Carolina, 494 U.S. 433 (1990), invalidating a capital sentencing requirement that juries must unanimously find mitigating factors before they can be considered, will not be applied retroactively to convictions final before those decisions.
http://supct.law.cornell.edu/supct/html/02-1603.ZS.html

Schriro v. Summerlin, 542 U.S. ___ (June 24, 2004)—The Court’s holding in Ring v. Arizona, 536 U.S. 584 (2002) that aggravating factors in death penalty proceedings must be decided by juries, not judges, would not be applied retroactively to convictions which were final when Ring was decided.
http://supct.law.cornell.edu/supct/html/03-526.ZS.html

Tennard v. Dretke, 543 U.S. ___ (June 24, 2004)—Defendant’s death sentence was reversed for failure of the Texas state court to allow evidence and to properly instruct the jury on the mitigating effect of the Defendant’s low IQ.
http://supct.law.cornell.edu/supct/html/2-10038.ZS.html

JURY TRIAL

Blakely v. Washington, 542 U.S. ___ (June 24, 2004)—Any facts increasing the sentence available for a convicted defendant must be found by a jury beyond a reasonable doubt, if not admitted by the defendant.
http://supct.law.cornell.edu/supct/html/02-1632.ZS.html

RIGHT TO COUNSEL

Iowa v. Tovar, 541 U.S. ___ (March 8, 2004)—The Sixth Amendment does not require courts to specifically warn defendants that a waiver of counsel in a criminal proceeding might cause them to overlook valid defenses or to inadequately analyze the decision to plead guilty. It is sufficient to satisfy the Sixth Amendment “if the defendant fully understands the nature of the right and how it would likely apply in general in the circumstances.…”
http://supct.law.cornell.edu/supct/html/02-1541.ZS.html

ARREST

Maryland v. Pringle, 540 U.S. ___ (December 15, 2003)—A police officer’s discovery of cocaine in a car’s rear-seat armrest established probable cause to arrest all of the car’s occupants, including the Defendant, who was neither the owner of the car nor its driver.
http://supct.law.cornell.edu/supct/html/02-809.ZS.html