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Criminal Procedure Keyed to Dressler
Dickerson v. United States
Citation:530 U.S. 428, 120 S.Ct. 2326, 147 L.Ed.2d 405.
The defendant was charged with bank robbery. He moved to suppress a statement he had made at a Federal Bureau of Investigation field office, on the grounds that he had not received “Miranda warnings” before being interrogated. The District Court granted it, but the Fourth Circuit reversed. The Fourth Circuit agreed with the District Court’s conclusion that the defendant had not received Miranda warnings before making his statement, but held that 18 U.S.C. § 3501, which in effect makes the admissibility of statements such as the defendant’s turn solely on whether they were made voluntarily, was satisfied in this case. It then concluded that Congress, by statute, has the final say on the question of admissibility.
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