Pennsylvania v. Muniz (1989)
- Docket
- 89-213
- Decided
- 1989-01-01
Summary
Question: Do incriminating utterances of a drunk-driving suspect constitute self-incrimination under the Fifth Amendment? Conclusion: No. Justice William J. Brennan, Jr. delivered the opinion of the 8-1 majority. The Supreme Court held that the Fifth Amendment distinguishes between real or physical evidence and testimonial evidence, of which only testimonial evidence is protected under the Amendment. Based on this analysis, the incriminating evidence drawn from physical evidence is admissible, but evidence drawn from the content of statements that relate factual information is not. The Court also held that the Fifth Amendment does not require the suppression of information not elicited by an officer. In his opinion concurring in part and dissenting in part, Chief Justice William H. Rehnquist wrote that answers to an officer’s questions should be admissible when the questions are meant to elicit responses to ascertain the suspect’s mental state. In such a case, the questions serve the same purpose as the field sobriety tests, and the answers are not testimonial. Justice Byron R. White, Justice Harry A. Blackmun, and Justice John Paul Stevens joined in the partial concurrence and partial dissent. In his separate opinion concurring in part and dissenting in part, Justice Thurgood Marshall wrote that creating an exception for routine booking questions and their answers undermined the rights the Miranda warning was meant to protect. He argued that the questions the police asked Muniz were intended to elicit incriminating responses, and because the police asked the questions before reading Muniz his Miranda rights, the evidence of the questions and their answers should be suppressed.