Lewin v. New Jersey
The Supreme Court declined to hear an appeal from a man convicted partly on statements he made to police before receiving Miranda warnings after a drunk-driving arrest.
Three justices dissented, arguing the Court should have taken the case to resolve a split among lower courts over whether Miranda warnings apply to traffic-offense arrests.
How it got here: A New Jersey trial court convicted the driver; the state appellate court affirmed; he asked the Supreme Court to review, which denied certiorari.
The Case in Depth
What happened
After a car accident, a man was arrested for driving under the influence and questioned at police headquarters before being given Miranda warnings. He was later charged with causing death through careless driving, and prosecutors used his pre-warning statements against him at trial. He was convicted and sentenced to a year in county jail.
The question before the Court
Do police have to read someone their Miranda rights before questioning them about a drunk-driving arrest?
Why it matters
People arrested for drunk driving or other traffic offenses in states following New Jersey's approach may be questioned by police and have their answers used against them at trial without first being told they have the right to remain silent or to a lawyer, since the Court left the lower-court split unresolved.
What changes now
Because certiorari was denied, the New Jersey conviction stands and the lower-court split over whether Miranda warnings apply to traffic-offense interrogations remains unresolved. No further proceedings occur in this case at the Supreme Court, though the underlying legal question could return in a future case.
What this does not decide
A denial of certiorari is not a ruling on the merits. The Supreme Court did not decide whether Miranda warnings must be given before questioning someone arrested for a traffic offense; it simply declined to review the New Jersey court's decision.
Concurrences and dissents
How the Justices voted
Dissent (1). Justice White (author).
Dissent — Justice White
“that the warnings were required when the person being interrogated was 'in custody at the station or otherwise deprived of his freedom of action in any significant way.’”Explaining the Miranda standard the dissent believed should apply regardless of offense type.
Justice White, joined by Justices Brennan and Stewart, argued the Court should have granted certiorari to resolve a conflict among lower courts over whether Miranda warnings apply to police questioning of people arrested for traffic offenses like drunk driving. He noted some courts exempt traffic arrests from Miranda while others apply the same custody-based rule as in any other case. Read the full dissent →
How the Court got there
The legal reasoning, step by step
- The dissent noted that Miranda v. Arizona and Orozco v. Texas require warnings whenever a person is in custody at the station or otherwise significantly deprived of freedom of action, regardless of the type of offense.
- The dissent observed that New Jersey courts had carved out an exception, holding that Miranda warnings need not be given to people arrested for motor vehicle violations like drunk driving before investigatory questioning.
- The dissent pointed out that several other courts had followed New Jersey's approach for traffic offenses and other misdemeanors, while other courts had rejected it and applied Miranda's custody-based rule regardless of offense type.
- Because lower courts were openly split on whether Miranda applies to traffic-offense interrogations, the dissenting justices concluded the conflict warranted the Court's review.
Doctrinal impact
Cases affected by this decision
Distinguishes Miranda v. Arizona (384 U. S. 436)
Lower courts split on whether Miranda's custody warning requirement extends to traffic-offense arrests.