Doyle v. Ohio
Citation and Court
426 U.S. 610 (1976) — Supreme Court of the United States
Facts
Doyle was arrested for selling marijuana. After receiving Miranda warnings he remained silent. At trial he presented an exculpatory story. The prosecution used his post-arrest silence following Miranda warnings to impeach him, suggesting he would have told his story to police if it were true.
Issue
Whether the Due Process Clause prohibits the use of a defendant’s post-arrest silence — following Miranda warnings — to impeach his exculpatory trial testimony.
Holding
Yes; it is fundamentally unfair and violates due process to use a defendant’s post-arrest silence to impeach his exculpatory trial testimony when that silence followed receipt of Miranda warnings.
Rule / Doctrine
Miranda warnings carry an implicit assurance that the government will not penalize the suspect for exercising the right to remain silent. Using post-Miranda silence to impeach at trial contradicts that implicit promise and is unconstitutional under the Due Process Clause. This protection applies even when the defendant’s silence might otherwise seem probative of guilt.
Significance
Established that post-Miranda silence is protected from use as impeachment, a rule that operates differently from pre-arrest silence (Jenkins v. Anderson) and differently from un-Mirandized silence (Fletcher v. Weir). Core to understanding the full scope of Miranda’s protection.