Interview and Interrogation: Supreme Court Cases Every Investigator Should Know

Interviewing and interrogation do not happen in a legal vacuum. Every decision made in an interview room, when to read the Miranda Warning, when when to ask questions, and when to stop, is shaped by decades of Supreme Court (SCOTUS) rulings interpreting the Fifth Amendment. These cases are not abstract legal theory; they directly govern how statement evidence is collected, challenged, and defended in court.

Judge in courtroom with gavel and scales

This post serves as a practical reference guide for investigators, supervisors, and trainers. The cases listed below form the constitutional backbone of modern interviewing and interrogation practices. Each one addresses a specific decision point investigators routinely face, from determining custody to recognizing interrogation, honoring invocations, and handling waivers. Together, they define the boundaries between lawful interviewing and constitutionally defective interrogation.

Interrogation: Miranda Framework

Miranda v. Arizona, 384 U.S. 436 (1966) - Ernesto Miranda was arrested in Phoenix based on circumstantial evidence linking him to a kidnapping and rape. After a lengthy police interrogation, he confessed to the crimes and signed a written statement indicating the confession was made voluntarily. Miranda was not informed that he had the right to remain silent, the right to consult an attorney, or that his statements could be used against him in court. At trial, he objected to the confession being admitted into evidence, arguing that he had not been aware of his rights. The objection was overruled, and Miranda was convicted and sentenced to 20 to 30 years in prison. His appeal was later denied by the Arizona Supreme Court.

Edwards v. Arizona, 451 U.S. 477 (1981) - After being arrested on a state criminal charge, the petitioner was advised of his Miranda rights and questioned by police on January 19, 1976. During that interview, he stated that he wanted an attorney, and questioning stopped. The following day, officers returned to the jail, told him they wanted to speak with him again, and once more advised him of his rights. The petitioner agreed to talk and gave a confession. At trial, the court denied his request to suppress the statement, finding it was voluntary, and he was ultimately convicted.

Berghuis v. Thompkins, 560 U.S. 370 (2010) - After being arrested in Michigan for a fatal shooting, Thompkins was taken into custody and advised of his Miranda rights. Police questioned him for nearly three hours. During that time, he said very little and did not ask to stop the interview or request a lawyer. Near the end of the questioning, an officer asked Thompkins whether he had prayed to God for forgiveness for the shooting, and Thompkins answered “yes.” That statement was later used as part of the case against him at trial.

Dickerson v. United States, 530 U.S. 428 (2000) - Dickerson was charged with bank robbery and related offenses after making statements to federal agents during questioning. He sought to suppress the statements, arguing that he had not been properly advised of his Miranda rights. The government relied on a federal statute intended to allow voluntary statements without Miranda warnings. The case centered on whether that statute could replace Miranda protections.

Law Enforcement Custody Determinations

Oregon v. Mathiason, 429 U.S. 492 (1977) - A burglary suspect was contacted by a police officer and asked to come to the police station to discuss the case. He arrived voluntarily, was told he was not under arrest, and was interviewed in an office with the door closed. During the conversation, the suspect admitted involvement in the burglary. He then left the station without being detained.

Howes v. Fields, 565 U.S. 499 (2012) - While serving a sentence in a Michigan prison, Fields was taken from his cell to a conference room and questioned by sheriff’s deputies about an unrelated crime. The interview lasted several hours and took place late at night. Fields was not restrained beyond normal prison conditions and was returned to his cell after the questioning. Statements from the interview were later used in court.

Stansbury v. California, 511 U.S. 318 (1994) - Police officers questioned Stansbury at a police station regarding a child’s death. During the interview, the officers began to suspect that Stansbury was involved in the crime. He was not told that he was under arrest, and the questioning continued as the officers’ suspicions developed.

Fifth Amendment: Invocation and Waiver of Rights

Michigan v. Mosley, 423 U.S. 96 (1975) - Mosley was arrested in connection with a robbery and questioned by police after being advised of his Miranda rights. During the interview, he stated that he did not want to discuss the robberies, and questioning stopped. Several hours later, a different officer questioned Mosley about an unrelated homicide after again advising him of his rights. Mosley made statements during the second interview that were later used at trial.

McNeil v. Wisconsin, 501 U.S. 171 (1991) - McNeil was arrested on an armed robbery charge and appeared at a court hearing where counsel was appointed for that case. While in custody, police later questioned him about unrelated offenses, advising him of his Miranda rights before the interrogation. McNeil made incriminating statements during the questioning, which were introduced at trial.

Maryland v. Shatzer, 559 U.S. 98 (2010) - Shatzer was incarcerated on an unrelated offense when police attempted to question him about allegations of sexual abuse. He declined to speak and requested an attorney, and questioning stopped. More than two years later, after Shatzer had been released back into the general prison population and later re-incarcerated, police questioned him again after advising him of his Miranda rights. He agreed to talk and made statements that were used in court.

Functional Interrogation and Police Conduct

Rhode Island v. Innis, 446 U.S. 291 (1980) - After being arrested for a robbery involving a missing shotgun, Innis was placed in a police vehicle and advised of his Miranda rights. He requested an attorney, and officers stopped questioning him. While transporting him, two officers spoke to each other about concerns that a child from a nearby school might find the weapon. Innis then interrupted the conversation and led officers to the shotgun.

Missouri v. Seibert, 542 U.S. 600 (2004) - Seibert was arrested in connection with a fatal fire and was questioned by police without being advised of her Miranda rights. During that initial interview, she made incriminating statements. Officers then paused the questioning, advised her of her rights, and resumed questioning, during which she repeated the earlier admissions. The statements were later introduced at trial.

Frazier v. Cupp, 394 U.S. 731 (1969) - Police took Frazier into custody and questioned him about a murder. During the interrogation, officers falsely told him that a co-suspect had already confessed. Frazier then made incriminating statements, which were later used against him at trial.

Interview and Interrogation: Right to Counsel

Moran v. Burbine, 475 U.S. 412 (1986) - Burbine was arrested in connection with a murder and advised of his Miranda rights. Unknown to him, a public defender contacted police and stated she would represent him, but officers did not inform Burbine of that call. Police questioned him, and he signed written waivers of his rights and made incriminating statements that were later introduced at trial.

Montejo v. Louisiana, 556 U.S. 778 (2009) - Montejo was arrested and brought before a judge, where counsel was appointed to represent him. Later that same day, police approached Montejo, advised him of his Miranda rights, and questioned him about the crime. Montejo agreed to talk and led officers to evidence used against him at trial.

Arizona v. Roberson, 486 U.S. 675 (1988) - Roberson was arrested in connection with a burglary and advised of his Miranda rights. During questioning, he requested an attorney, and the interview stopped. Several days later, while still in custody, a different officer questioned him about an unrelated robbery after advising him of his rights. Roberson made statements during the second interview that were later used in court.

Juveniles and Special Considerations

J.D.B. v. North Carolina, 564 U.S. 261 (2011) - A 13-year-old student was removed from his classroom by police and school officials and questioned in a closed room at school about neighborhood burglaries. He was not advised of his Miranda rights during the interview. The questioning occurred in the presence of school authorities, and the student eventually made incriminating statements that were later introduced in juvenile court.

Fare v. Michael C., 442 U.S. 707 (1979) - A 16-year-old juvenile was taken into custody and questioned by police in connection with a murder. After being advised of his Miranda rights, he asked to speak with his probation officer rather than an attorney. Police denied the request and continued questioning, during which the juvenile made incriminating statements that were later introduced in court.

Statement Admissibility and Reliability

Jackson v. Denno, 378 U.S. 368 (1964) - Jackson was convicted of murder in New York after police introduced a confession he claimed was coerced. At trial, the jury was allowed to hear the confession and was instructed to decide both whether the confession was voluntary and whether Jackson was guilty. Jackson argued that this process was unfair because the same jury deciding guilt also evaluated the confession’s voluntariness. His confession played a significant role in his conviction.

Colorado v. Connelly, 479 U.S. 157 (1986) - Connelly approached a police officer and stated that he had killed someone. After being advised of his Miranda rights, he gave a detailed confession. It was later revealed that Connelly was experiencing severe mental illness at the time and claimed that his confession was compelled by hallucinations. His statements were admitted at trial.

Culombe v. Connecticut, 367 U.S. 568 (1961) - Culombe, a man with limited intellectual ability, was questioned repeatedly by police over several days in connection with a murder. He eventually confessed after prolonged detention and questioning. His confession was introduced at trial and played a central role in his conviction.

Conclusion

Taken together, these Supreme Court cases form the constitutional framework that governs modern interviewing and interrogation in the United States. Across decades of decisions, the Court has repeatedly emphasized concerns about custody, pressure, voluntariness, and the reliability of statements offered as evidence. Science-Based Interviewing (SBI) aligns naturally with this body of law because it rejects accusatory and psychologically coercive tactics in favor of research-supported communication practices. By focusing on information gathering, free narratives, and how people actually communicate and respond under stress, SBI strengthens the quality of statement evidence while staying squarely within constitutional boundaries established by the Supreme Court.