United States v. John W. Hinckley, Jr. United States of America v. John W. Hinckley, Jr
672 F.2d 115 · Court of Appeals for the D.C. Circuit · 1982
Facts
On March 30, 1981, the President of the United States, his Press Secretary, a Secret Service agent, and a Metropolitan Police Department officer were shot in an assassination attempt in front of the Hilton Hotel in Washington, D.C. John W. Hinckley, Jr. was apprehended at the scene. While in custody, Hinckley was advised of his Miranda rights and requested to speak with an attorney before answering questions. Despite this request, FBI agents questioned Hinckley for approximately one-half hour before he had an opportunity to consult with his attorney, obtaining 'background' information. Months later, while Hinckley was a pretrial detainee undergoing mental evaluation at the Federal Correctional Institution in Butner, North Carolina, prison guards read his personal papers during a routine cell search for contraband. Several sheets of handwritten notes bearing on alleged criminal activity were seized by prison authorities and turned over to federal officials.
Procedural history
In a pretrial ruling, the district court suppressed certain evidence, finding it was obtained in violation of constitutional protections. The government brought an expedited appeal to this court, arguing the district court erred in its findings and conclusions, or alternatively, that the evidence should be usable under novel theories.
Issue
Did FBI agents violate Hinckley's Fifth Amendment rights by questioning him after he requested an attorney, constituting an impermissible interrogation? Did prison guards violate Hinckley's Fourth Amendment rights by reading and seizing his personal notes during a cell search? Can evidence obtained in violation of constitutional rights be used at trial to rebut an insanity defense?
Holding
Yes, the FBI questioning violated Hinckley's Fifth Amendment rights, and the evidence obtained was properly suppressed. Yes, the prison guards' reading and seizure of Hinckley's notes violated his Fourth Amendment rights, and that evidence was properly suppressed. No, illegally obtained evidence cannot be used to rebut an insanity defense; therefore, the district court's suppression order was affirmed.
Rule
The Fifth Amendment's Miranda rule establishes a per se rule that if an individual states they want an attorney, interrogation must cease until an attorney is present, unless the accused initiates further communication. Interrogation includes express questioning or its functional equivalent, meaning words or actions police should know are reasonably likely to elicit an incriminating response, which includes systematic 'background' interviews when mental state is a likely issue. The Fourth Amendment protects pretrial detainees, who retain some privacy rights consistent with prison security; arbitrary invasions of privacy are prohibited, and reading personal papers without institutional policy or immediate security threat is unreasonable. Illegally obtained evidence is generally inadmissible, and this exclusionary rule is not curtailed to allow such evidence to rebut an insanity defense, as doing so would undermine the deterrence rationale of constitutional protections.
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