Rhode Island v. Innis, , is a decision by the United States Supreme Court

Supreme Court of the United States

The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 that clarifies what constitutes "interrogation" for the purposes of Miranda warnings. Under Miranda v. Arizona

Miranda v. Arizona

Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...

, police are forbidden from interrogating a suspect once he has asserted his right to counsel

Right to counsel

Right to counsel is currently generally regarded as a constituent of the right to a fair trial, allowing for the defendant to be assisted by counsel , and if he cannot afford his own lawyer, requiring that the government should appoint one for him/her, or pay his/her legal expenses...

 under the Fifth Amendment

Fifth Amendment to the United States Constitution

The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...

. In Innis, the court held that interrogation is not just direct questioning but also its "functional equivalent."

Facts

Innis was arrested in connection with an earlier robbery of a taxicab driver with a sawed-off shotgun. Upon arrest, Innis received his Miranda warnings, to which he responded that he understood his rights and wished to speak to an attorney. Innis was then placed in a police car to be driven to the central police station. The three officers placed with transporting Innis were instructed not to question or intimidate him in any way. On their way to the station, the officers began a discussion showing concern about the missing shotgun from the robbery. One of the officers stated that there were “a lot of handicapped children running around in this area” because a school for such children was located nearby, and “God forbid one of them might find a weapon with shells and they might hurt themselves.” Innis then interrupted them, and showing concern for the kids, asked the officers to turn back so he could show them the weapon. As the officers searched for the weapon, Innis was again read his Miranda rights, to which he acknowledged understanding but nonetheless was concerned for the kids in the area. At trial, Innis moved to suppress the shotgun and his statements. The lower court denied the motion to suppress, while the Rhode Island Supreme Court held Innis was entitled to a new trial.

U.S. Supreme Court decision

The court held that the Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent. So, “interrogation” under Miranda refers not only to express questioning, but also to 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. Here, there was no express questioning of Innis. The conversation between the two officers was, at least in form, nothing more than a dialogue between them to which no response from respondent was invited. This does not raise to the level of “functional equivalent” of questioning, since it cannot be said that the officers should have known that their conversation was reasonably likely to elicit an incriminating response from Innis. Under this standard, any knowledge that the police might have concerning unusual susceptibility of the defendant to a particular form of persuasion might be an important factor in determining whether the police should have known that their words or actions were reasonably likely to elicit an incriminating response from the suspect.
There is nothing to suggest that the officers were aware that respondent was peculiarly susceptible to an appeal to his conscience concerning the safety of handicapped children. In this case, Innis' statement were viewed as voluntary and thus not barred by the Fifth Amendment

Fifth Amendment to the United States Constitution

The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...

. In contrast to Brewer v. Williams

Brewer v. Williams

Brewer v. Williams, , is a decision by the United States Supreme Court that clarifies what constitutes "interrogation" for the purposes of Miranda warnings. Under Miranda v. Arizona, police are forbidden from interrogating a suspect once he has asserted his right to counsel under the Sixth Amendment...

, , where the court found that the police's knowledge of Brewer's deeply religious beliefs were exploited to illicit an incriminating statement and thus were in violation of his rights.