Rhode Island v Innis

On January 12, 1975, a cab driver who was reported as missing was found dead. The driver had been shot in the back of the head by a shotgun blast. Five days later on the seventeenth, another cab driver reported being robbed by a man with a shotgun. Provided with pictures, the driver was able to point out Thomas Innis as the perpetrator. Soon after, an officer with the Rhode Island police spotted Innis walking down the street and aprehended him. This officer informed him of his rights, and when two senior officers came to the scene, they made sure he understood his rights as well. Innis then told officers that before he spoke to them he wanted his attorney present. The officers suspected that he had gotten rid of the shotgun used in the crime not long before his arrest, meaning it was probably nearby. In a four-door van used to transport prisoners, two officers sat in the front seats while another sat in the back with Innis. On the way to the station, one officer up front struck up conversation, pointing out to the other officer next to him that it would be a shame if a child got hurt, as there was a school for the handicapped close by. At this, Innis led the officers to where the gun was, also concerned for the children’s safety. Later, Innis’ defense argued that the information obtained was through an innovative interrogation tactic from police, and was unlawfully obtained due to a violation to Innis’ “Miranda Rights,” as established in Miranda.

Justice Stewart, who gives the opinion of the Court, points out that an interrogation is, by the standards decided in Miranda, defined as “words or actions on the part of officers that they should have known were reasonably likely to elicit a response.” He also points out that, as stated in Miranda as well, “Volunteered statements are not barred by the Fifth Amendment.” These two major ideas being laid out, the question comes down to whether or not the officers intended for Innis to confess based on their conversation, and if the information received was probed intentionally. Stewart argues that because the officers have no knowledge of why handicapped children’s health would have a significant impact on Innis, and he was not mentally restrained or impaired at the time, that his statements that led to the discovery of the gun were voluntary, and constitutional. Justice Marshall, writing for the dissent, agrees with the Court’s definitions and boundaries of legal interrogation, but argues that the conversation between officers was an obvious attempt to coerce information. It was 4:30 A.M., which could have left Innis not thinking clearly. Furthermore, this all took place less than a mile from the arrest, which would give notions of premeditation from the officer. Also, appeals to handicapped children are amongst the most sympathetic one can make.

I do not agree with Justice Marshall. I think it is very grey whether or not the officers did this intentionally, but there’s definitely not enough evidence to say for sure that they coerced this information. I believe that this does apply as a voluntary statement, as there was no pressure in the least for Innis. Also, there was no reason for the officers to presume Innis would appeal sympathetically, as he had just shot someone in the head as a result of robbery. While the officers may have planted that conversation, there was no reason or expectation for Innis to come forward, and was done so completely from his own will to protect the children, which is admittedly admirable, despite his past actions.

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