The defendant was on trial for selling a controlled substance to an undercover police officer. At the time of his arrest, police secured statements from the defendant in violation of his Miranda protections. The defendant testified at trial that the contents of the bag sold to the officer were represented as a controlled substance but was actually baking powder. This testimony contradicted those statements obtained in violation of his Miranda rights. On cross-examination, the prosecution asked the defendant if he recalled making incriminating statements after his arrest. The defendant testified that he could not recall those statements.
Whether the government can introduce statements that were obtained in violation of the defendant’s Miranda rights to impeach his testimony?
Yes. The government is permitted to introduce statements that were obtained in violation of the defendant’s Miranda rights but only for the limited purposes of impeaching his testimony.
The prosecution may not use Miranda-tainted statements in its case-in-chief. However, that does not preclude the use of these statements altogether. The Court noted that the impeachment process serves an invaluable function to the jury in assessing a witness’ credibility. The defendant’s right to testify does not include a right to commit perjury. Provided that the statements were trustworthy, such evidence can be used to impeach the defendant’s testimony.401 U.S. 222, 91 S. Ct. 643 (1971
401 U.S. 222, 91 S. Ct. 643 (1971)