''Wainwright v. Greenfield'', 474 U.S. 284 (1986), is a case in which the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

reversed the lower court's finding and overturned the petitioner's conviction, on the grounds that it was fundamentally unfair for the

prosecutor A prosecutor is a legal representative of the prosecution in states with either the common law adversarial system or the Civil law (legal system), civil law inquisitorial system. The prosecution is the legal party responsible for presenting the ...

to comment during the court proceedings on the petitioner's silence invoked as a result of a

Miranda warning In the United States, the ''Miranda'' warning is a type of notification customarily given by police to criminal suspects in police custody (or in a custodial interrogation) advising them of their right to silence and, in effect, protection fr ...

Background

After his arrest in

Florida Florida is a state located in the Southeastern region of the United States. Florida is bordered to the west by the Gulf of Mexico, to the northwest by Alabama, to the north by Georgia, to the east by the Bahamas and Atlantic Ocean, and to ...

for

sexual battery Battery is a criminal Offence (law), offense involving unlawful physical contact, distinct from assault which is the act of creating apprehension of such contact. Battery is a specific common law offense, although the term is used more general ...

, Greenfield was given three separate

Miranda warnings In the United States, the ''Miranda'' warning is a type of notification customarily given by police to criminal suspects in police custody (or in a custodial interrogation) advising them of their right to silence and, in effect, protection fr ...

. Each time, he exercised his right to remain silent and requested to speak with an attorney before answering questions. At his trial in the Circuit Court for

Sarasota County Sarasota County is a county located in Southwest Florida. At the 2020 US census, the population was 434,006. Its county seat is Sarasota and its largest city is North Port. Sarasota County is part of the North Port–Sarasota–Bradenton, FL m ...

, 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, arguing that Greenfield's silence after receiving

was evidence of his sanity. 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".. Greenfield then unsuccessfully sought

habeas corpus ''Habeas corpus'' (; from Medieval Latin, ) is a recourse in law through which a person can report an unlawful detention or imprisonment to a court and request that the court order the custodian of the person, usually a prison official, t ...

relief in

Federal District Court The United States district courts are the trial courts of the U.S. federal judiciary. There is one district court for each federal judicial district, which each cover one U.S. state or, in some cases, a portion of a state. Each district cou ...

, by suing the

Florida Department of Corrections The Florida Department of Corrections operates state prisons in the U.S. state of Florida. It has its headquarters in Florida's capital of Tallahassee. The Florida Department of Corrections operates the third largest state prison system in the ...

and its secretary,

Louie L. Wainwright Louie Lee Wainwright (September 11, 1923 – December 23, 2021) was an American corrections administrator who served as Secretary of the Florida Department of Corrections from 1962 to 1987. He is known for having been the named respondent in two ...

, arguing that the prosecutor's use of his silence violated the

Due Process Clause In United States constitutional law, a Due Process Clause is found in both the Fifth and Fourteenth Amendments to the United States Constitution, which prohibits arbitrary deprivation of "life, liberty, or property" by the government except as ...

of the Fourteenth Amendment as construed in '' Doyle v. Ohio'' (1976). 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.

Decision

The Court held that the prosecutor's use of respondent's post-arrest, post-Miranda warnings silence as evidence of sanity violated the

of the Fourteenth Amendment.

Footnotes

External links

* {{caselaw source , case = ''Wainwright v. Greenfield'', {{ussc, 474, 284, 1986, el=no , courtlistener =https://www.courtlistener.com/opinion/111553/wainwright-v-greenfield/ , justia =https://supreme.justia.com/cases/federal/us/474/284/ , loc =http://cdn.loc.gov/service/ll/usrep/usrep474/usrep474284/usrep474284.pdf , oyez =https://www.oyez.org/cases/1985/84-1480 United States Supreme Court cases United States Supreme Court cases of the Burger Court United States Fifth Amendment self-incrimination case law 1986 in United States case law Sarasota County, Florida

Background

Decision

See also

Footnotes

Further reading

External links