Doyle v. Ohio

Doyle v. Ohio, 426 U.S. 610 (1976), is a United States Supreme Court case regarding the Due Process rights of the Fourteenth Amendment.

Doyle v. Ohio
Argued February 23, 1976
Decided June 17, 1976
Full case nameDoyle v. Ohio
Citations426 U.S. 610 (more)
96 S. Ct. 2240; 49 L. Ed. 2d 91
Holding
The defendant's silence in response to a Miranda warning cannot be used against them.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinions
MajorityPowell, joined by Burger, Brennan, Stewart, White, Marshall
DissentStevens, joined by Blackmun, Rehnquist
Laws applied
U.S. Const. amend. XIV, X

Holding

The Supreme Court held that the criminal defendant's silence in response to a Miranda warning cannot be used to impeach them during cross examination.

In 1980 a similar case, Jenkins v. Anderson, reached the Supreme Court, its ruling distinguishing it from Doyle. The Court ruled that the prosecution is permitted to exploit as inculpatory evidence a defendant's failure to disclose an exculpatory testimony eventually presented in trial as defense, to government officials such as police in a prompt manner before the arrest. The petitioner in this case had committed murder and, weeks later, confessed to the crime but, in the process, embroidered the narrative by claiming self-defense as the justification. The prosecution mooted this during trial as evidence of guilt and perjury. After habeas corpus relief, the Supreme Court upheld the conviction, recognizing no breach of the Fourteenth Amendment.[1]

Salinas v. Texas (2013) expanded this ruling, ruling that mere silence during prearrest interrogations is inadequate when attempting to employ the right to silence, and instead, a suspect must unambiguously invoke the right verbally.

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See also

References
  1. Jenkins v. Anderson, 447 U.S. 231 (1980).

Further reading
  • O'Keefe, F. R. (1976). "Impeaching a Defendant's Testimony by Proof of Post-Arrest Silence: Doyle v. Ohio". Cleveland State Law Review. 25 (2): 261–296. ISSN 0009-8876.
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