Harris v. New York
Citation and Court
401 U.S. 222 (1971) — Supreme Court of the United States
Facts
Harris was arrested and made statements to police before being given the Miranda warnings required by Miranda v. Arizona. At trial, the prosecution used these statements not as direct evidence of guilt, but to impeach Harris after he took the stand and gave testimony inconsistent with his prior statements.
Issue
May the prosecution use statements obtained in violation of Miranda to impeach a defendant who testifies in his own defense at trial?
Holding
Yes; statements inadmissible in the prosecution’s case-in-chief because of Miranda violations may nonetheless be used for impeachment purposes if the statements were made voluntarily.
Rule / Doctrine
Miranda-defective but voluntary statements may be used to impeach a testifying defendant’s credibility. The exclusionary rule bars use of such statements as substantive evidence of guilt but does not prevent their use to expose testimonial inconsistencies, because defendants do not have a right to commit perjury.
Significance
Harris limits the reach of Miranda by creating an impeachment exception. It reflects the Court’s view that Miranda’s purpose is to deter unconstitutional conduct, not to give defendants a license to commit perjury. The rule is subject to the limitation that statements obtained through actual coercion remain wholly inadmissible.