Doyle v. Ohio

Background

Two men were arrested and tried separately for selling ten pounds of marijuana after an undercover buy. At the scene an agent gave them Miranda warnings. Each man later took the stand and said a third person had framed them, but neither had told that story at the time of arrest. At trial the prosecutor asked why they had not told the arresting agent about the alleged frame, and the trial courts allowed the questions. State appeals courts affirmed the convictions.

Reasoning

The Court considered whether a prosecutor may impeach a defendant by pointing out that the defendant was silent after arrest and after receiving Miranda warnings. The majority held that such use of post-arrest silence is unfair. Because Miranda warnings tell an arrestee he may remain silent, any silence after those warnings is ambiguous and may simply reflect the exercise of the right to remain silent. Using that silence to undermine a later explanation, the Court said, violates the Due Process Clause. The Court therefore reversed the convictions and sent the cases back to state court for further proceedings.

Real world impact

The decision prevents prosecutors from calling jurors' attention to a defendant's silence after arrest when the defendant had received Miranda warnings. It requires trial courts and prosecutors to avoid using post-arrest silence to attack credibility, and it may lead to retrials or new proceedings in affected cases.

Dissents or concurrances

A dissent by Justice Stevens (joined by Justices Blackmun and Rehnquist) argued the silence could be probative and that the convictions should have been affirmed.