Moran v. Burbine
Citation and Court
475 U.S. 412 (1986) — Supreme Court of the United States
Facts
Burbine was arrested and, while in custody, an attorney retained by his sister called the police station and was told no interrogation would occur that night. Police did not inform Burbine of the call, then proceeded to obtain his waiver of Miranda rights and elicit a confession. He argued his waiver was invalid because he did not know about the attorney’s call.
Issue
Whether police conduct that misleads a suspect’s attorney and withholds that information from the suspect invalidates an otherwise knowing and voluntary Miranda waiver.
Holding
No; Burbine’s waiver of his Miranda rights was valid. The failure to inform a suspect of his attorney’s call, while perhaps unethical, does not render a waiver of Miranda rights constitutionally invalid.
Rule / Doctrine
A valid Miranda waiver requires only that it be made knowingly, intelligently, and voluntarily based on what the suspect knows. It does not require that police inform suspects of all information that might affect their decision, including the existence of an attorney trying to reach them. Events outside the suspect’s knowledge cannot bear on the validity of his knowing waiver.
Significance
Confirmed that the Miranda inquiry is focused on the suspect’s own state of mind, not on police conduct toward third parties. Police deception of attorneys (as distinct from deception of suspects themselves) does not automatically vitiate a Miranda waiver.