Precedent in Rhode Island v. Innis (1980)

The case of Rhode Island v. Innis (1980) addresses whether or not indirect questions and actions by police count as an interrogation under the Fifth Amendment’s Miranda rights provision. In January 1975, a cabdriver was found dead after being killed with a bullet to the back of the head. Several days later, a tip from another cabdriver led the police to Thomas Innis, who was later arrested, read his rights and searched. The police found him to be unarmed, but believed he had hidden the gun somewhere. Innis was again read his rights by more senior police officers, to which Innis acknowledged that he understood his rights and requested an attorney during all questioning. He was then placed in a car with three other officers, who had been told not to talk to Innis. While driving around, two of the officers discussed how important it was to find the gun, since there were a lot of handicapped children in the area, and thus it was possible that one of the could find the gun and hurt themselves. Innis, overhearing the conversation, admitted that did not want children getting hurt and led the police to the gun. Later, at trial, Innis was convicted of murder, and then appealed on the grounds that he was being interrogated, in violation of his Miranda rights.

For me, the biggest issue with this case is the circumstances. The Court ruled that this was not an interrogation, since police actions and words can only violate the Firth Amendment when it is “reasonably likely to illicit an incriminating response from the suspect” (Rhode Island v. Innis, 2). This case established the precedent that interrogation is not just limited to direct questions but also includes any other methods the police may use to try and get information from a suspect.

While I agree with this precedent, I am not sure that this case should have been used to create it. While the Court argues that the officers did not mean to include Innis in the conversation, it it hard to know if this is true or not. In Justice Marshall’s dissenting opinion, he points out that there were three officers in the car with Innis, a fact also included in the original case facts. What is not mentioned in the original case facts is that two of the officers were in front, but another officer was in the back seat with Innis (Rhode Island v. Innis, 3) I have a hard time believing that it is routine for a police officer to sit in the back seat of a caged car with a suspected criminal. There is a reason why a barrier is placed between the criminal and the officers.

Furthermore, Justice Marshall points out that the car only travelled a mile before Innis offered to lead them to the gun. He argues that this meant they must have started the conversation as soon as they got in the car, or pretty soon after (Rhode Island v. Innis, 3). Additionally, there is a good chance that Innis may have faced a moral dilemma over whether or not to tell the cops, which could have taken several minutes as well before he felt as though he had to say something. Justice Marshall also brings up that the topic of the conversation, centered around protecting the children, is a classic interrogation technique since it encourages the suspect to “display some evidence of decency and honor” (Rhode Island v. Innis, 3).

When all of this is considered, it becomes clear that at best this case is flawed. While I do agree with the precedent, it seems that it is possible that this case violates the same precedent it establishes. For me, this does not seem like the right way to establish such an important precedent. Is it possible that future criminals could attempt to use this flawed case as grounds to overturn their own convictions or suppress evidence?