Dmack-Doyle V. Ohio
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Jan 9, 2024
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Case Briefing Practice-Doyle v. Ohio
DaWonda L Mack
Indiana Wesleyan University CRJ-465--01A: Constitutional Law/Civil Liber
Susan Biery Sergojan
December 4, 2023
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Case Briefing Practice-Doyle v. Ohio
I. Identifying Information
Doyle v. Ohio, 426 U.S. 610 (1976). The vote was 6 in favor and three against. Justice
Lewis F. Powell, Jr. wrote the majority opinion.
II. Circumstances of the Case
The petitioner, Jefferson Doyle, faced the charge of selling a narcotics bureau informant ten pounds of Marijuana. Known local dealer William Bonnel assisted the informant with the sale, with Doyle being the intended purchaser of the Marijuana. Based on the transaction date, an agreed-upon total was set at $1750 for the ten pounds of narcotics, with the narcotics team only collecting $1320. The transaction between Bonnel and Doyle was unsupervised by the narcotics unit. After the transaction competition, Doyle was pulled over and arrested for participation in the sale.
Doyle did not attest to the charges until he took the stand at trial and claimed
Bonnel set him up during the sale. Doyle’s claim insists that his only interest was purchasing
one or two pounds, not the agreed-upon ten. Doyle also stated that Bonnel threw the bag of
money into his car, took the Marijuana, and then drove away. Prosecution agents questioned Doyle on why he hadn’t informed the agent of this incident at the time of his arrest, and Doyle stated that with his silence, he protected his Fifth Amendment right. The courts reversed the conviction based on the ruling that impeachment purposes of the petitioner's silence violates the Fourteenth Amendment Due Process Clause.
III. The Issue Presented and the Court’s Decision
Due to his silence until the court trial, the impeachment of Doyle's claim of innocence violated his due process.
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IV. The Court’s Reasoning
The Court held that the use for impeachment purposes of a defendant's silence at the
time of arrest and after receiving Miranda warnings violates the Due Process Clause of
the Fourteenth Amendment. The Fifth Amendment clearly states that a person taken into custody
by law enforcement has the right to remain silent, and anything said can and will be used against the individual in a court of law. Even with law enforcement officers verbally confirming the deal
took place, they lacked the transaction on video surveillance, which left questioning the validity of what occurred during the actual transaction. Doyle had no obligation to proclaim his innocence until the court hearing occurred. There’s also the lack of a rebuttal by the prosecution to Doyle’s recollection of the incident, along with the claim
that his silence throughout his arrest was reason enough to believe he wasn’t being honest. The Court ruled that silence is a protected right, and a case reversal of the
charges was granted.
V. Concurring/Dissenting Opinions
In his dissent, Justice John Stevens argued that giving Miranda warnings does not
lessen the probative value of a defendant's silence. The opinion relies on the fact that the
petitioners in this case, when cross-examined about their silence, did not offer reliance
on Miranda warnings as a justification.
VI. Your Response
I agree with the majority in Doyle v. Ohio. If someone is arrested, just because they do
not proclaim the use of their rights doesn’t mean that their rights don’t exist. Our justice
system operates rightfully on the idea that someone must be proven guilty beyond a
reasonable doubt. If the prosecution cannot perform under these circumstances,
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then defendants like Doyle are to be found not guilty.
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References
Doyle v. Ohio, 426 U. S. 610 (1976)
Case Name Supreme Court Reporter Volume and Page Year Decided
Doyle v. Ohio
426 U.S. 610
1976