Orozco v.

Texas
PONENTE: JUSTICE BLACK
DOCTRINE: The guidelines set by Miranda are not restricted to custodial
interrogations held in police stations. The court in this case emphasized that it is
absolutely necessary for officers to give the described warnings when the person
being interrogated was "in custody at the station or otherwise deprived of his
freedom of action in any significant way."

RELEVANT LAW/S IN THIS CASE:

FOURTEENTH AMENDMENT: No person shall be compelled in any criminal
case to be a witness against himself.
FACTS: Petitioner, Reyes Arias Orozco, was convicted of murder without
malice and was sentenced to serve in the penitentiary for a term of two to
ten years. The facts show that petitioner fought with the victim in front of a
restaurant in Dallas during the night of said shooting. The fight broke after
the deceased allegedly spoke to petitioners female companion. The men
were said to have thrown against each other, not only punches but also
harsh words. Before the shot was fired, the deceased supposedly called
petitioner, Mexican Grease. After the incident, Orozco went back to his
apartment. Around 4am, four officers entered his room and began to
question him. During the interrogation that transpired in his room,
petitioner admitted that he was at the scene of the crime when the incident
happened; that he owned a pistol, and such was currently hidden in washing
machine in his boarding house.
During the trial for the case, the judge, despite the objection of petitioners
counsel, allowed one of the four officers to relay petitioners admission
during the aforementioned questioning.
ISSUE: W/N PETITIONERS ADMISSION WAS INVALIDLY AND UNLAWFULLY
OBTAINED BY THE FOUR OFFICERS?
RULING: YES. The use of these admissions obtained in the absence of the
required warnings was a flat violation of the Self-Incrimination Clause of the
Fifth Amendment as construed in Miranda. It is true that the Court did say
in Miranda that "compulsion to speak in the isolated setting of the police
station may well be greater than in courts or other official investigations,
where there are often impartial observers to guard against intimidation or
trickery." But the opinion iterated and reiterated the absolute necessity for

officers interrogating people "in custody" to give the described warnings. In

this particular case, one of the officers even admitted that from the moment
Orozco gave his name, he was not free to go where he pleased, but was
"under arrest." Therefore, the Miranda doctrine applies as the same declared
that the warnings were required when the person being interrogated was "in
custody at the station or otherwise deprived of his freedom of action in any
significant way."
DISSENT/S:
JUSTICE WHITE & JUSTICE STEWART
The Court now extends the same rules to all instances of in-custody
questioning outside the station house. Once arrest occurs, the application
of Miranda is automatic. The rule is simple but it ignores the purpose
of Miranda to guard against what was thought to be the corrosive influence
of practices which station house interrogation makes feasible. The Court
wholly ignores the question whether similar hazards exist or even are
possible when police arrest and interrogate on the spot, whether it be on the
street corner or in the home, as in this case. No predicate is laid for believing
that practices outside the station house are normally prolonged, carried out
in isolation, or often productive of the physical or psychological coercion
made so much of in Miranda.