Based on these findings, the Fourth Circuit concluded that "§ 3501, enacted at the invitation of the Supreme Court and pursuant to Congress's unquestioned power to establish the rules of procedure and evidence in the federal courts, is constitutional." Therefore, the court held that "the admissibility of confessions in federal court is governed by § 3501, rather than the judicially created rule of Miranda."

Miranda Survives

On June 26, 2000, the U.S. Supreme Court reaffirmed the Miranda decision. In Dickerson v. United States, the Supreme Court held that Miranda, "being a constitutional decision of th[e] Court, may not be in effect overruled by an Act of Congress,..." The Court also declined to overrule Miranda itself, and declared "that Miranda and its progeny in this Court govern the admissibility of statements made during custodial interrogation in both state and federal courts."

Cases and Codes

• Miranda v. Arizona, 384 U.S. 436 (1966).

• United States v. Dickerson, 166 F.3d 667 (4th Cir. 1999).

• U.S. Constitution: Fifth Amendment Includes annotations of cases decided by the United States Supreme Court.

• 18 U.S.C. § 3501: Admissibility of Confessions

Resources

• Supreme Court Center Features party and amicus curiae briefs from the Dickerson v. United States case.

• FindLaw's Criminal Law Center: Police Questioning: When Miranda Warnings Are Required An article by Nolo Press.

• American Civil Liberties Union ACLU Amicus Curiae Brief in United States v. Dickerson in Support of Rehearing. U.S. Court of Appeal s, Fourth Circuit.

• Beyond Miranda By Edward M. Hendrie, J.D., a legal instructor at the FBI Academy.

• Intentional Violations of Miranda: A Strategy for Liability By Kimberly A. Crawford, J.D., a legal instructor at the FBI Academy.

• Miranda Rights From American Treasures of the Library of Congress. Online exhibit includes Chief Justice Warren's handwritten notes concerning the Miranda decision and Justice Brennan's comments on the Miranda decision.

• Miranda v. Arizona Features the oral argument, docket, abstract, voting, and annotations. From The Oyez Project, Northwestern University.

• "Police Interrogation in the 1990s: An Empirical Study of the Effects of Miranda" By Professor Paul G. Cassell and Bret S. Hayman. 42 UCLA L. Rev. 839 (1996)