Berghuis v. Thompkins (2009)
- Docket
- 08-1470
- Decided
- 2009-01-01
Summary
Question: 1) Did the Sixth Circuit improperly expand the Miranda rule when it held that defendant's Fifth Amendment rights were violated? 2) Did the Sixth Circuit fail to give the state court deference when it granted habeas corpus relief with respect to defendant's ineffective counsel argument when there was substantial evidence of the defendant's guilt? Conclusion: Yes. Yes. The Supreme Court reversed the Sixth Circuit, holding that the state court's decision to reject Mr. Thompkins' Miranda claim was correct. With Justice Anthony M. Kennedy writing for the majority, the Court reasoned that Mr. Thompkins failed to invoke his Miranda rights to remain silent and to counsel because he failed to do so "unambiguously." Moreover, the Court reasoned that Mr. Thompkins waived his Miranda right to remain silent when he "knowingly and voluntarily" made a statement to the police. The Court further held that, even if Mr. Thompkins' counsel was ineffective, he cannot show he was prejudiced by counsel's deficient performance – a prerequisite to establishing that his Sixth Amendment right was violated. Justice Sonia Sotamayor, joined by Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen G. Breyer, dissented. She reprimanded the majority for retreating from the broad protections afforded by Miranda , stating that now a criminal suspect waives his rights simply by uttering a "few one-word responses."