Wainwright v. Greenfield

Infobox SCOTUS case
Litigants = Wainwright v. Greenfield
ArgueDate = November 13
ArgueYear = 1985
DecideDate = January 14
DecideYear = 1986
FullName = Louie L. Wainwright, Secretary, Florida Department of Corrections v. Greenfield
USVol = 474
USPage = 284
Citation =
Prior =
Subsequent =
Holding = The prosecutor's use of respondent's postarrest, post-Miranda warnings silence as evidence of sanity violated the Due Process Clause of the Fourteenth Amendment.
SCOTUS = 1981-1986
Majority = Stevens
JoinMajority = Brennan, White, Marshall, Blackmun, Powell, O'Connor
Concurrence = Rehnquist
JoinConcurrence = Burger
LawsApplied =

"Wainwright v. Greenfield", 474 U.S. 284 (1986), is a case in which the United States Supreme Court reversed the lower court's finding, overturning the petitioner's convicting, saying that it was fundamentally unfair for the prosecutor to comment during the court proceedings on the petitioner's silence invoked as a result of a Miranda warning. [cite web
url=http://books.google.com/books?id=w5_jF7YIPzYC&pg=PA456&lpg=PA456&dq=louie+l+wainwright&source=web&ots=30XTbe3eJs&sig=cuYnsMtApQAT96gvo_5ii9ue0g4
title=The American Dictionary of Criminal Justice: Key Terms and Major Court Cases
publisher=Scarecrow Press
accessdate=2007-10-06]

ummary of complaint

The respondent entered a plea of not guilty by reason of insanity to a charge of sexual battery. At his trial in the Circuit Court for Sarasota County, Florida, the prosecutor argued that respondent's silence after receiving Miranda warnings was evidence of his sanity. The question presented is whether such use of a defendant's silence violates the Due Process Clause of the Fourteenth Amendment as construed in "Doyle v. Ohio" (1976).

Circumstances

After his arrest in Florida for sexual battery, respondent was given three separate Miranda warnings, and each time he exercised his right to remain silent and requested to speak with an attorney before answering questions. Subsequently the respondent pleaded not guilty by reason of insanity. In the prosecutor's closing arguments in the Florida trial court, the prosecutor reviewed the police officer's testimony, over defense counsel's objection. 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".cite web |url=http://supreme.justia.com/us/474/284/ |title= Wainwright v. Greenfield, 474 U.S. 284 (1986) |publisher=Justia Supreme Court Center
accessdate=2007-10-06 ]

Respondent then unsuccessfully sought habeas corpus relief in Federal District Court suing the Florida Department of Corrections and its secretary, Louie L. Wainwright which affirmed the conviction, holding that the general rule precluding 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 Due Process Clause of the Fourteenth Amendment.

ee also

*List of United States Supreme Court cases, volume 474

Footnotes

Further reading

*cite journal |last=Matz |first=A. L. |authorlink= |coauthors= |year=1985 |month= |title=The Sounds of Silence: Post-Miranda Silence and the Inference of Sanity |journal=Boston University Law Review |volume=65 |issue= |pages=1025 |issn=00068047 |url= |accessdate= |quote=
*cite journal |last=McHugh |first=M. C. |authorlink= |coauthors= |year=1985 |month= |title="Greenfield v. Wainwright": The Use of Post-Miranda Silence to Rebut the Insanity Defense |journal=American University Law Review |volume=35 |issue= |pages=221 |issn=00031453 |url= |accessdate= |quote=