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Supreme Court · Decisions

Rhode Island v. Innis

The Court, clarifying what counts as interrogation under Miranda, held that interrogation includes not just direct questioning but also its functional equivalent, meaning police words or actions reasonably likely to elicit an incriminating response.· AI-written

446 U.S. 291 · No. 78-1076 · 1979 term · Burger Court

Decided May 12, 1980 · argued Oct 30, 1979

Criminal procedure · Miranda warnings

Majority opinion: Potter Stewart

The voteMajorityDissent

6–36 in the majority, 3 in dissent

3 dissents (6–3)

Vacated and remanded. Rhode Island won.

What this ruling means

Vacated and remanded: the Supreme Court set aside the decision of the Rhode Island Supreme Court, wiping it out without necessarily saying the result was wrong, and sent the case back for that court to decide again under the right legal standard.

Rhode Island was the petitioner, the side that asked the Supreme Court to review the case. “Won” means the Court gave that side the result it asked for.

From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.

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Summary

The opening of the case’s Wikipedia article: what the case was about and what the Court held.

Rhode Island v. Innis, 446 U.S. 291 (1980), 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. In Innis, the court held that interrogation is not just direct questioning but also its "functional equivalent"; namely, "any words or actions on the part of the police ... that the police should know are reasonably likely to elicit an incriminating response."

Read the full article on Wikipedia

Data notes

The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.

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How the justices voted

Each justice who took part, placed by their Martin–Quinn ideology score for the 1979 term. Filled: the 6 in the majority. Hollow: the 3 in dissent. Colour is the party of the president who appointed them.

More liberalMore conservativeMedianMarshallBrennanStevensBlackmunWhiteStewartPowellBurgerRehnquist

Majority(6)

Dissent(3)

Data notes

Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.

Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.

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The parties

Who brought the case to the Court, who answered it, and how it got there.

Petitioner
Rhode IslandState (Rhode Island)
Respondent
InnisPerson accused, indicted, or suspected of crime
Reached the Court by
Certiorari (the Court chose to hear it)
Data notes

The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.

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The law at issue

The law the Court was asked to apply, and the kind of power it used to decide.

Provision
Fifth Amendment (Miranda warnings)
Kind of law
Constitutional Amendment
Decided by
Judicial review (state level)
Data notes

The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.

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Timeline

What happened at the Court and how the case got there, newest first.

  1. May 12, 1980DecidedDecided · Decided 6–3: vacated and remanded. Rhode Island won.
  2. Oct 30, 1979ArguedArgued · Oral argument before the Court.
  3. Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari).
  4. Not datedCourt belowCourt below · Decided by the Rhode Island Supreme Court: reversed, with a dissent.
  5. Not datedBeganBegan · The case began in the Rhode Island trial court.
Data notes

From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.

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Other decisions on the same issue

39 other argued cases since 1946 on miranda warnings, newest first.

  1. Vega v. Tekoh142 S. Ct. 2095Jun 23, 2022 · 142 S. Ct. 2095Criminal procedure6–36–3 band

  2. Carol Howes, Warden, Petitioner v. Randall Lee Fields565 U.S. 499Feb 21, 2012 · 565 U.S. 499Criminal procedure6–36–3 band

  3. J. D. B., Petitioner v. North Carolina564 U.S. 261Jun 16, 2011 · 564 U.S. 261Criminal procedure5–45–4 band

  4. Mary Berghuis, Warden v. Van Chester ThompkinsLandmark · Right to remain silent560 U.S. 370Jun 1, 2010 · 560 U.S. 370Criminal procedure5–45–4 band

  5. Maryland v. Michael Blaine Shatzer, Sr.559 U.S. 98Feb 24, 2010 · 559 U.S. 98Criminal procedure9–0Unanimous band

  6. Florida v. Kevin Dewayne Powell559 U.S. 50Feb 23, 2010 · 559 U.S. 50Criminal procedure7–27–2 band

  7. United States v. Samuel Francis Patane542 U.S. 630Jun 28, 2004 · 542 U.S. 630Criminal procedure5–45–4 band
  8. Missouri v. Patrice Seibert.542 U.S. 600Jun 28, 2004 · 542 U.S. 600Criminal procedure5–45–4 band

  9. Michael Yarborough, Warden v. Michael Alvarado541 U.S. 652Jun 1, 2004 · 541 U.S. 652Criminal procedure5–45–4 band

  10. Charles Thomas Dickerson v. United States530 U.S. 428Jun 26, 2000 · 530 U.S. 428Criminal procedure7–27–2 band

  11. Robert L. Davis v. United States512 U.S. 452Jun 24, 1994 · 512 U.S. 452Criminal procedure9–0Unanimous band

  12. Robert Edward Stansbury v. California511 U.S. 318Apr 26, 1994 · 511 U.S. 318Criminal procedure9–0Unanimous band

  13. Robert S. Minnick v. Mississippi498 U.S. 146Dec 3, 1990 · 498 U.S. 146Criminal procedure6–27–2 band
  14. Pennsylvania v. Inocencio Muniz496 U.S. 582Jun 18, 1990 · 496 U.S. 582Criminal procedure8–18–1 band

  15. Illinois v. Lloyd Perkins496 U.S. 292Jun 4, 1990 · 496 U.S. 292Criminal procedure8–18–1 band

  16. Duckworth v. Eagan492 U.S. 195Jun 26, 1989 · 492 U.S. 195Criminal procedure5–45–4 band
  17. Arizona v. Roberson486 U.S. 675Jun 15, 1988 · 486 U.S. 675Criminal procedure6–27–2 band

  18. Greer, Warden v. Miller483 U.S. 756Jun 26, 1987 · 483 U.S. 756Criminal procedure6–36–3 band
  19. Arizona v. Mauro481 U.S. 520May 4, 1987 · 481 U.S. 520Criminal procedure5–45–4 band
  20. Connecticut v. Barrett479 U.S. 523Jan 27, 1987 · 479 U.S. 523Criminal procedure7–27–2 band
  21. Moran, Superintendent, Rhode Island Department of Corrections v. Burbine475 U.S. 412Mar 10, 1986 · 475 U.S. 412Criminal procedure6–36–3 band
  22. Oregon v. ElstadLandmark470 U.S. 298Mar 4, 1985 · 470 U.S. 298Criminal procedure6–36–3 band
  23. Berkemer, Sheriff of Franklin County, Ohio v. McCarty468 U.S. 420Jul 2, 1984 · 468 U.S. 420Criminal procedure9–0Unanimous band

  24. New York v. Quarles467 U.S. 649Jun 12, 1984 · 467 U.S. 649Criminal procedure5–45–4 band
  25. Oregon v. Bradshaw462 U.S. 1039Jun 23, 1983 · 462 U.S. 1039Criminal procedure5–45–4 band
  26. Edwards v. Arizona451 U.S. 477May 18, 1981 · 451 U.S. 477Criminal procedure9–0Unanimous band

  27. Fare, Acting Chief Probation Officer v. Michael C.442 U.S. 707Jun 20, 1979 · 442 U.S. 707Criminal procedure5–45–4 band
  28. North Carolina v. Butler441 U.S. 369Apr 24, 1979 · 441 U.S. 369Criminal procedure5–36–3 band
  29. Doyle v. Ohio426 U.S. 610Jun 17, 1976 · 426 U.S. 610Criminal procedure6–36–3 band
  30. United States v. Mandujano425 U.S. 564May 19, 1976 · 425 U.S. 564Criminal procedure8–0Unanimous band

  31. Beckwith v. United States425 U.S. 341Apr 21, 1976 · 425 U.S. 341Criminal procedure7–18–1 band
  32. Michigan v. Mosley423 U.S. 96Dec 9, 1975 · 423 U.S. 96Criminal procedure6–27–2 band

  33. United States v. Hale422 U.S. 171Jun 23, 1975 · 422 U.S. 171Criminal procedure9–0Unanimous band
  34. Oregon v. Hass420 U.S. 714Mar 19, 1975 · 420 U.S. 714Criminal procedure6–27–2 band
  35. Michigan v. Tucker417 U.S. 433Jun 10, 1974 · 417 U.S. 433Criminal procedure8–18–1 band
  36. Harris v. New York401 U.S. 222Feb 24, 1971 · 401 U.S. 222Criminal procedure5–45–4 band
  37. Orozco v. Texas394 U.S. 324Mar 25, 1969 · 394 U.S. 324Criminal procedure6–27–2 band
  38. Mathis v. United States391 U.S. 1May 6, 1968 · 391 U.S. 1Criminal procedure5–36–3 band

  39. Miranda v. ArizonaLandmark · Right to counsel384 U.S. 436Jun 13, 1966 · 384 U.S. 436Criminal procedure5–45–4 band

Data notes

Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.

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Official record

Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.