Parties:
Harry J. Berkemer, Sherriff of Franklin County (Plaintiff) vs. McCarty (Defendant)
Facts: The police stopped McCarty for driving while intoxicated. McCarty responded to all the questions asked by the police during the traffic stop. After that, he was put in jail. However, McCarty claims that the police never read him his Miranda rights.
Prior Proceedings: This case was initially presented before the State appeal court, which affirmed McCarty's conviction. In the ruling process, the court noted that Miranda did not apply to misdemeanors. The supreme court in Ohio dismissed the appeal made by McCarty. After that, McCarty filed a habeas petition before the Federal District Court. However, it is noted that the federal court dismissed the appeal, arguing that Miranda did not apply for criminal offenses. The appeal was reversed by the Sixth Circuit Court, maintaining that Miranda applies regardless of whether the offense was a misdemeanor or a felony. Certiorari was then granted by the U.S. Supreme court to establish a resolution for the confusion between State and Federal courts.
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Issues Presented or Questions of Law:
Does questioning of motorists by the roadside after a traffic stop amount to custodial interrogation for Miranda? No .
When a person has been subjected to custodial interrogation associated with a misdemeanor traffic offense, does the Miranda rule apply to the person? Yes .
Judgment:
The decision made by the Sixth Circuit Court of Appeals, which provided that Miranda applies regardless of whether the offense is a demeanor or a felony, was withheld.
Rule of Law or Legal Principle Applied:
The first rule of law applied was that the Miranda rule is applicable to everyone and all the cases regardless of whether the cases are demeanor or felony. Secondly, it was established that police stop interrogations are not meant to create an environment and feeling of "being in custody" since they are often conducted in public and within short times.
Reasoning:
When people are subjected to custodian interrogation or coercive atmosphere, they must be informed of their constitutional rights first. During the time of conducting interrogations, the police often do not know the severity of the possible charges. The rulings made do not depend on whether someone is about to be charged or has been charged with a misdemeanor or felony. If the law has to be fully enforced, the establishment of Miranda exceptions for misdemeanors must be avoided to prevent confusion in the process. Miranda's rule is often simple and clear. Thus the exception of misdemeanor cases would compromise the simplicity and clarity of the rule. As such, it can be argued that the statements made by McCarty in jail after being subjected to custodian interrogation were inadmissible.
Additionally, when police stop someone in an ordinary traffic stop, the environment established is not sufficient to create a feeling of being "in custody." All the traffic stops occur in public and take a short time. For someone in custody, the environment and the atmosphere established are always dominated by the police, which is not the case with traffic stops. By analyzing the facts, in this case, it is evident that McCarty believed he was not free to leave. Thus he developed a feeling of being "in custody," only after formally being arrested.
Significance:
In many courts, before the case of Berkemer v. McCarty, the Miranda rights were only read for defendants charged with critical offenses. Thus, this case is significant because it has helped establish an understanding that the Miranda rule applies regardless of whether the case involved is a demeanor or a felony.
