Summary of Rhode Island v. Innis, Supreme Court of United States (1980)

Respondent/Defendant: Innis, the defendant was arrested for murder of a taxi driver and robbery of another taxi driver. At the time of the arrest the defendant was unarmed and the officers read the Miranda warnings to the defendant on two different occassions and the defendant asked for a lawyer. The officers did not find the weapon and the defendant was placed in a caged wagon to be transported to the police station. On their way to the police station, two of the transporting officers started a conversation. The conversation was about the little handicap children finding the defendant’s gun and then shooting themselves. The defendant could not take it any longer and he intervened and told the officers to return to the arresting spot so he can show them where the weapon was. The weapon was used as evidence to convice the defendant. The Supreme Court of Rhode Island reversed the conviction by ruling that the defendant was interrogated after he had invoked his Miranda right.

Issue: Did the conversation between the two officers mount up to the level of custodial interrogation?

Holding: No

Key Facts: According to Miranda v. Arizona, all custodial questioning should stop when a person asks for an attorney.

Legal Reasoning: The court first defined custodial interrogation. The court stated the interrogation is “questioning intiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.” The court went a step further and ruled that custodial interrogation also includes “any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.” The court ruled that in the current case, the officers never included the defendant in their conversation and their conversation was not of the nature which would have made an officer reasonably believe that it would likely elicit incriminating response from the defendant. So the ruling of the lower court was reversed and the conviction stood.