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Dickerson v. United States


The defendant was arrested for bank robbery. He made several incriminating statements in violation of his Miranda protections. The government attempted to admit these statements into evidence through the use of a federal statute enacted after the Miranda v. Arizona decision that permitted the introduction of statements into evidence solely on whether they were made voluntarily. An appellate court allowed the government to use the federal statute because it did not disrupt a constitutional standard.


Whether Miranda warnings are constitutional in nature?


Yes. The Supreme Court held that the Miranda warnings are a constitutional rule and may not be reduced by Congressional intervention.


In Miranda v. Arizona, the Court set out “concrete constitutional guidelines for law enforcement agencies and courts to follow.” Congress’ enactment of the federal statute was an effort to overturn the ruling of Miranda. In certain circumstances, this is acceptable. “Congress retains the ultimate authority to modify or set aside any judicially created rules of evidence and procedure that are not required by the Constitution.” However, “Congress may not legislatively supersede our decisions interpreting and applying the Constitution.”

Here, the Court noted that the history of Miranda is that it had constitutional dimension as its interpretations had consistently been applied to the states. The Court noted that it has no “supervisory power over the courts of the several States.” The Supreme Court’s “authority is limited to enforcing the commands of the United States Constitution.” As the statute relied upon by the government does not provide the full protections found in the Miranda decision, that statute is unconstitutional. The Court explicitly rejected the notion of overruling the Miranda decision as it “has become embedded in routine police practice to the point where the warnings have become part of our national culture.”


530 U.S. 428, 120 S. Ct. 2326 (2000)

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