Impact of Rhode Island v. Innis on Miranda Rights

Question: Can you discuss the impact of the 1980 case of Rhode Island v. Innis on Miranda rights?

Answer: So what Rhode Island v. Innis basically stands for is that the Miranda safeguards come into play whenever a person in custody is subject either to express questioning or to basically the functional equivalent of express questioning. In this particular case, a person was arrested in connection with a taxi cab robbery, or robbery of a taxi cab driver using a sawed-off shotgun. He did not have the shotgun there, and so the police start questioning him. 

There were three officers that were basically transporting Innis to the police station. They were told to not question him during that time. But while they’re transporting him, the two or three officers in the vehicle start discussing the fact that this area was near a school with handicap kids and it would be a shame if one of these handicap kids found the gun and the shells and ended up injuring themselves. So they were basically playing on emotion or compassion that a child or handicap child may be hurt in this case if the gun was found. And it worked, because the defendant or the suspect in the case told them where the gun was.

So the court looked at that, and in this particular case, said that that was OK; however, they did kind of lay down a rule of the functional equivalent to custodial interrogation is still protected. So in other words, an interrogation doesn’t have to be express questioning. It could be any type of questions that are reasonably, that the police should know are reasonably likely to elicit a response from the person being detained.

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