Riddell v. Rhay, Penitentiary Superintendent

Background

Mr. Riddell was convicted in state court of assault after a rifle he carried discharged and struck his neighbor in the foot during an argument about a dog. At trial the main question was intent: Riddell testified he did not mean for the rifle to fire. The prosecution, however, confronted him with a prior statement he gave to police — obtained without Miranda warnings — in which he said he “cocked the hammer and pulled the trigger” and intended only to scare the neighbor.

Reasoning

The Court refused to hear Riddell’s challenge, leaving in place the rule from last Term’s Harris decision that statements obtained in violation of Miranda may be used to impeach a defendant if the defendant testifies inconsistently. Justice Douglas, joined by Justice Brennan, dissented from the denial of review. He argued that allowing such impeaching use removes the incentive for police to follow Miranda, undermines the Fifth Amendment protection against compelled testimony, and risks introducing unreliable, coercively obtained statements to juries.

Real world impact

The practical effect is to let lower-court rulings stand that permit prosecutors to use statements taken without Miranda warnings to attack a defendant’s credibility at trial. Justice Douglas warned this will likely encourage some interrogators to ignore requests for counsel, because a damaging statement can still be used if the defendant later testifies. This was a dissent from denial of review, not a final ruling on the merits, so future Court action could change the rule.

Dissents or concurrances

Justice Douglas’s dissent, joined by Justice Brennan, called for granting review and stressed the government should not be able to profit from its own failure to protect a suspect’s constitutional rights.