Lanier v. South Carolina

Background

A man convicted of armed robbery said his confession should have been suppressed because police arrested him illegally. The South Carolina Court of Appeals assumed the arrest might have been illegal but upheld the confession anyway, saying a statement given in custody is admissible if it was voluntary. The state supreme court declined further review, and the case came to the United States Supreme Court.

Reasoning

The Court examined whether a confession that is voluntary for Miranda purposes is automatically free from the taint of an illegal arrest. Relying on earlier cases cited in the opinion, the Court said Miranda voluntariness alone does not necessarily remove the Fourth Amendment problem created by an illegal arrest. Because the South Carolina court’s reasoning conflicted with those precedents, the Supreme Court vacated the judgment and sent the case back for further proceedings.

Real world impact

Lower courts must not treat Miranda warnings and a defendant’s apparent willingness to talk as the only test when an illegal arrest is alleged. Instead, courts will need to analyze whether the illegal arrest tainted the confession under the relevant precedents. The ruling sends this case back to the state court to apply that analysis and decide whether the confession should be suppressed.

Dissents or concurrances

Justice O’Connor (joined by Justice Rehnquist) said courts on remand can consider the timing, frequency, and likely effect of Miranda warnings when deciding taint. Justice Marshall objected to the summary disposition because the parties had no prior notice or chance to brief the full merits.