Rhode Island v. Innis
Citation and Court
446 U.S. 291 (1980) — Supreme Court of the United States
Facts
After his arrest for murder, Innis invoked his right to counsel. While being transported, two officers conversed between themselves about the danger the missing shotgun posed to children in the area. Innis interrupted and led them to the weapon. The State argued this was not “interrogation” triggering Miranda.
Issue
What constitutes “interrogation” for purposes of Miranda v. Arizona?
Holding
Interrogation under Miranda includes not only express questioning but also its functional equivalent — any words or actions by police that they should know are reasonably likely to elicit an incriminating response from the suspect.
Rule / Doctrine
The Miranda safeguards apply to express questioning and to its “functional equivalent” — any police conduct (words or actions) that police know or should know is reasonably likely to elicit an incriminating response. The standard is objective: would a reasonable officer know the conduct was likely to produce a response? The officers’ conversation in Innis did not meet this standard because they could not have known it would prompt Innis to speak.
Significance
Defined the operative scope of the Miranda rule by setting the standard for what constitutes interrogation. Critical for understanding when Miranda protection is triggered: the functional equivalent test captures indirect pressure that is just as coercive as direct questioning.