479 U. S. 564
January 27, 1987
Three criminal procedures cases from Colorado in less than two months? The Colorado Supreme Court must really have been out of it during the mid-1980s. On to the case – John Leroy Spring committed homicide, and a few weeks later, Bureau of ATF officials detained him, ostensibly on the charge of possessing stolen firearms. But after giving Spring the Miranda warning, which he waived, the ATF officials questioned him about the murder, which led to some potentially incriminating statements. Spring argued that these statements should be suppressed, because he had been tricked into making them, since he had not expected to be questioned about the murder.
In a 7-2 ruling, the Court held that Spring’s statements were admissible. Writing for the Court, Powell said that Spring had unquestionably made the voluntary decision to waive his Miranda privilege, and that the police did not coerce responses in any way. Examining the Miranda decision, Powell found no support for the claim that police officers had a duty under that ruling to tell suspects about the topics of questioning at the beginning. Finally, because the officers never lied to Spring, he could not claim that he had been “tricked” into waiving his privilege.
You can probably guess who the two dissenters were. Marshall wrote, and Brennan joined. He argued that knowledge of the topics of questioning was critically important to a suspect’s decision whether or not to waive. He also made the point that pulling a bait and switch in interrogation could be considered inherently coercive for a suspect who has previously waived his rights.
Personally, if I were being interrogated, I would definitely want to know what topics the questioning would cover. That said, Powell’s legal case was better than Marshall’s. Miranda is not a Constitutional command, but a prophylactic protection, and Spring’s circumstances simply weren’t dire enough to justify expanding the extra-constitutional rule further.