Read below to learn about landmark court cases from Phoenix, AZ.
- Miranda v. Arizona (1966)
If you have watched Law and Order, or any other crime TV, you are familiar with the Miranda warning: “You have the right to remain silent. Anything you say can and will be used against you in the court of law. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you.” The Miranda rights are the result of a landmark court case from Phoenix, AZ—Miranda v. Arizona.
When Phoenix resident Ernesto Miranda was arrested for rape, kidnapping, and robbery in 1963, he was not informed of his Fifth Amendment right against self-incrimination or his Sixth Amendment right to an attorney before police began to interrogate him, during which he confessed. Miranda had not finished ninth-grade and had a history of mental illness. He was sentenced to 20 to 30 years in prison based solely on his confession.
The U.S. Supreme Court in a 5-4 decision ruled that the confession could not be used as evidence because the police failed to inform Miranda of his right to an attorney and his right against self-incrimination before the interrogation. The Miranda rights purpose is to prevent police from using violence, coercion, and intimidation during interrogations, which can lead to false confessions. Only after being informed of your rights, can a defendant knowingly and intelligently waive them and agree to make a statement.
- Arizona v. Evans (1995)
Arizona v. Evans was a landmark case from Phoenix, Arizona that expanded the exclusionary rule. The exclusionary rule states that the government cannot use evidence obtained illegally in federal court. The rule was intended to deter police misconduct and protect individual rights. In 1961, Mapp v. Ohio extended the exclusionary rule to the states.
There are some exceptions to the exclusionary rule. One of the exceptions is the good faith exception. The good faith rule, created in 1984, stated that if the police believed in good faith that a warrant was legal, but it later turned out to be technically flawed, the evidence collected during the search was still admissible. Arizona v. Evans considered whether this rule could be expanded and if the exclusionary rule applied to clerical errors made by judicial officers.
The case arose in 1991 when the Phoenix Police pulled over Isaac Evans for driving the wrong way down a one-way street. After running his license, the computer showed there was a warrant out for his arrest. The police arrested Evans, and during his arrest, they searched Evans’ car, found marijuana, and charged him with possession. Generally, police need a warrant to search a vehicle, but they are permitted to search incident to an arrest without a warrant. Later it was discovered that the arrest warrant had been quashed and only remained due to a technical error made by the court clerk. Evans argued that the court should exclude the evidence of marijuana because the police discovered it during an illegal arrest.
The case reached the U.S. Supreme Court, which held that the evidence of marijuana was admissible. The Court stated that the exclusionary rule does not apply to a clerical error made by a court employee.
- Clark v. Arizona (2006)
The landmark case Clark v. Arizona upheld Arizona’s use of evidence relating to insanity. Eric Clark, a diagnosed paranoid schizophrenic, killed a police officer during a traffic stop. To be guilty of murder, the Arizona government must prove that the defendant has the required intent to murder. Clark wanted to use expert evidence about his mental disorder not only to prove that he was insane but also to prove that he could not have had the requisite intent. The Arizona trial court and the Arizona Court of Appeals held that evidence of his mental state could only be introduced in relation to his insanity defense. He was sentenced to 25 years to life in prison.
In a 5-4 decision, the U.S. Supreme Court held that Arizona could limit the use of expert evidence about a defendant’s mental state to his insanity defense. A defendant is presumed sane until he proves otherwise. The majority held that allowing a defendant to use evidence of his mental state to prove he did not possess the requisite intent would enable him to get around this presumption.
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