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At trial, the appellant, Ernesto Miranda, objected to the admission of evidence obtained during a police interrogation by coercion. The Arizona Supreme Court held that the appellant’s constitutional rights had not been violated and affirmed the judgement of the lower court.

Facts

Ernesto Miranda was arrested and identified by the complaining witness. Miranda was then interrogate by two detectives who testified that they had not informed Miranda of his right to remain silent or to have counsel. The confession obtained from the detectives’ interrogation was then used at trial to convict Miranda to 20-30 years in prison.

Issue

Are the privileges given in the 5th and 6th amendments applicable to custodial interrogation? In other words: outside of trial.

Rule

The 5th Amendment. Which states that no person can be compelled to be a witness against themselves. And the 6th Amendment which states that a person shall have assistance of counsel for their defense.

If the interrogation proceeds without an attorney, the Justices said, a heavy burden lies on the state to demonstrate that the defendant knowingly and intelligently waived his privilege.

Analysis

In this case, the appellant was confined to unfamiliar surroundings, uninformed, and unaware of his fifth amendment right to silence and 6th amendment right to counsel. The Court ruled that the typed statement of volition at the header of Miranda’s written statement was insufficient demonstration that the defendant (appellant here) had knowingly and intelligently waived his 5th and 6th amendment privileges, suggesting that the detectives may have taken advantage of the defendant’s indigence.

Conclusion

The Court reversed the rulings of the lower courts because Miranda had not been apprised of his rights and the waiver of rights given by the state did not reach the Court’s accepted standards for the waiver of constitutional rights: that the defendant knowingly and intelligently did so.

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Preceding History

McClung prevailed in federal district court by arguing that his business was small and had no impact on interstate commerce. He received an injunction barring the enforcement of the Civil Rights Act against his restaurant, Ollie’s Barbecue.

Facts

Now Ollie’s Barbecue was a family owned restaurant in Birmingham Alabama – located on a state highway, 11 blocks away from an interstate highway. The restaurant had refused served black people since its opening in 1927, though it did provide a take-out service for them.

In the District Court, it was found that in the 12 months preceding the passage of the Civil Rights Act, the restaurant had purchased locally approximately $150,000 worth of food, $69,000 – nearly half – of which was meat that it bought from a local supplier who had procured it from outside the State, indicating that a substantial portion of the food served in the restaurant had moved in interstate commerce.

Despite this finding, the district court concluded that if Ollie’s Barbecue were required to serve black people, it would lose a substantial amount of business and, furthermore, that in passing the Civil Rights Act, Congress had legislated a conclusive presumption that a restaurant affects interstate commerce if it serves or offers to serve interstate travelers or if a substantial portion of the food which is serves has moved in commerce.

The district court held that Congress could not do this because there was no demonstrable connection between food purchased in interstate commerced and sold in a restaurant and the conclusion that discrimination in the restaurant would affect that commerce.

Issue/Question

Can the Civil Rights Act of 1964 prohibit discrimination against people, in this case black people, by a restaurant?

Rule

“That appellee’s own contribution to demand for wheat may be trivial by itself is not enough to remove him from the scope of federal regulation where, as here, his contribution, taken together with that of many others similarly situated is far from trivial.” Wickard v. Filburn, 317 U.S. 111

Analysis

In this case, McClung was of the belief that, because his restaurant was so small, it didn’t have enough of an affect on commerce for it to be subject to Congress’ regulation – that his one, measly little restaurant was far from likely to impede transient patronage to the extent that it would impact the whole of United State’s economy.

The Supreme Court disagreed, for the same reason they delivered the Wickard decision I mentioned earlier; they even backed it up with evidence. The Court cited a comparison of per capita spending by black people in restaurants, theaters, and similar establishments. The comparison indicated less spending, after discounting income differences, in areas where discrimination was widely practiced.

Conclusion

To conclude, the Court restated its centuries old position on the issue: that the power of congress in this field [commcerce] is broad and sweeping; where it keeps within its sphere and violates no express constitutional limitation, the Court will not interfere. They reversed the judgement of the lower, district court, and held that the Civil Rights Act of 1964, as applied in this case, was plainly appropriate.

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Follow The Case Space on Twitter!
Check out the website for written briefs and the blog: https://www.thecase.space/
Find more episodes: https://www.podcast.thecasespace.org/

Fact Summary

First, a brief summary of the facts: Brian Dailey was, at the time, a five year old visiting Naomi Garratt at Naomi’s sister Ruth’s house. Garratt contended that just as she was about to resume sitting in a lawn chair she had been sitting in, Dailey pulled it out from under her which caused her injury.

Now this seems like not that big a deal but for the fact that Garrett actually fractured her hip. To cover the costs associated with her injury,

Garrett sought $11,000 in damages. In 1955.

A lower court found in favor of Dailey and the Plaintiff appealed – giving us the opinion that we are reading today from the Washington Supreme Court.

Rule of Law

There is a heavy focus when it comes to the torts of Assault and Batter on the intentionality of the act. Did the defendant have the intention to inflict or otherwise cause bodily harm against the plaintiff? And basically the rule of law that the Court ended up with was this: a minor who has committed a tort with force is liable as any other would be. BUT a plaintiff must establish that the defendant committed the act with the intention of causing the harmful contact. Specifically in the case, a phrase that gets reused a lot is “knew with substantial certainty,” as in Dailey would had to have known with substantial certainty that his action of removing the chair could result in injury.

Issue

The question here is this: in an action for battery, what amounts to willful and unlawful intent?

Conclusion

Intent is apparent where a defendant possessed knowledge of substantial certainty that an injury would occur as a result of their actions.

The case was remanded to the lower courts to discover whether Dailey did know with substantial certainty that Garratt would attempt to sit in the lawn chair that had been moved.