Wainwright v. Greenfield

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Wainwright v. Greenfield
Seal of the United States Supreme Court.svg
Argued November 13, 1985
Decided January 14, 1986
Full case name Louie L. Wainwright, Secretary, Florida Department of Corrections v. Greenfield
Citations 474 U.S. 284 (more)
Holding
The prosecutor's use of respondent's postarrest, post-Miranda warnings silence as evidence of sanity violated the Due Process Clause of the Fourteenth Amendment.
Court membership
Case opinions
Majority Stevens, joined by Brennan, White, Marshall, Blackmun, Powell, O'Connor
Concurrence Rehnquist, joined by Burger

Wainwright v. Greenfield, 474 U.S. 284 (1986), is a case in which the United States Supreme Court reversed the lower court's finding and overturned the petitioner's conviction, on the grounds that it was fundamentally unfair for the prosecutor to comment during the court proceedings on the petitioner's silence invoked as a result of a Miranda warning.[1]

Summary of complaint[edit]

The respondent entered a plea of not guilty by reason of insanity to a charge of sexual battery. At his trial in the Circuit Court for Sarasota County, Florida, the prosecutor argued that respondent's silence after receiving Miranda warnings was evidence of his sanity. The question presented is whether such use of a defendant's silence violates the Due Process Clause of the Fourteenth Amendment as construed in Doyle v. Ohio (1976).[2]

Circumstances[edit]

After his arrest in Florida for sexual battery, respondent was given three separate Miranda warnings. Each time, he exercised his right to remain silent and requested to speak with an attorney before answering questions. Subsequently, the respondent pleaded not guilty by reason of insanity. During closing arguments in the Florida trial court, the prosecutor reviewed the police officer's testimony, over defense counsel's objection. The testimony described the occasions when respondent had exercised his right to remain silent. The prosecutor suggested that respondent's repeated refusals to answer questions without first consulting an attorney "demonstrated a degree of comprehension that was inconsistent with his claim of insanity".[2]

Respondent then unsuccessfully sought habeas corpus relief in Federal District Court, by suing the Florida Department of Corrections and its secretary, Louie L. Wainwright. The court affirmed the conviction, holding that the general rule precluding a prosecutor from commenting on a defendant's exercise of his right to remain silent did not apply to a case in which an insanity plea was filed.[2]

Decision[edit]

The Court held that the prosecutor's use of respondent's post-arrest, post-Miranda warnings silence as evidence of sanity violated the Due Process Clause of the Fourteenth Amendment.[2]

See also[edit]

Footnotes[edit]

  1. ^ "The American Dictionary of Criminal Justice: Key Terms and Major Court Cases". Scarecrow Press. Retrieved 2007-10-06. 
  2. ^ a b c d "Wainwright v. Greenfield, 474 U.S. 284 (1986)". Justia Supreme Court Center. Retrieved 2007-10-06. 

Further reading[edit]

  • Matz, A. L. (1985). "The Sounds of Silence: Post-Miranda Silence and the Inference of Sanity". Boston University Law Review 65: 1025. ISSN 0006-8047. 
  • McHugh, M. C. (1985). "Greenfield v. Wainwright: The Use of Post-Miranda Silence to Rebut the Insanity Defense". American University Law Review 35: 221. ISSN 0003-1453.