The Ninth Circuit Court Rules Miranda Rights Don’t Apply to Warrant-Backed Civil Immigration Arrests
The Ninth Circuit Court has upheld an order to deport a Mexican citizen, Jose Maria Zuniga De La Cruz, who had argued he was coerced into admitting his illegal status under an administrative warrant. Miranda rights are the formal warning given by law enforcement to individuals in custody of their right to silence and an attorney. However, a panel of the Ninth Circuit Court has ruled that Miranda rights don’t apply to warrant-backed civil immigration arrests.
Background: Miranda Rights and Deportation Proceedings
Miranda rights are the product of the 1966 Supreme Court decision in Miranda v. Arizona, in which the court ruled law enforcement could not use statements by defendants against themselves while in custody unless they were first informed of their rights to a lawyer and against self-incrimination. Miranda rights have been a topic of debate in the context of deportation proceedings as, in civil deportation proceedings, the substantial distinctions between them and criminal trials make Miranda warnings irrelevant
The Ninth Circuit Panel’s Decision
A three-judge panel from the Ninth Circuit Court affirmed earlier rulings by an immigration judge and the U. S. Board of Immigration Appeals and rejected Zuniga’s appeal to the court. The panel asserted that the substantial distinctions between civil deportation proceedings and criminal trials make Miranda warnings inappropriate in the deportation context. The court’s judgment explains that it’s the nature of the proceeding, and not the nature of the arrest, that is relevant. The court stated that Zuniga’s focus on the warrant was misplaced because the immigration court must follow the law, which requires them to thoroughly “scrutinize the reliability and credibility of the evidence before them, to include any statements made during the course of the deportation proceedings,” regardless of whether those statements are the products of Miranda warnings.
Different Opinions from Judges
All three judges of the Ninth Circuit panel signed the decision, with Circuit Judge Salvador Mendoza – a Biden appointee – arguing that even though Miranda applies only to criminal proceedings, there’s no reason for noncitizens not to be informed of their rights. The author of the lead opinion, Circuit Judge Daniel Bress – a Trump appointee – disagreed, arguing that Miranda is not authority for creating new versions of itself in the immigration context.
Police Cleared in Shooting of Black Man in Ohio
In a related incident, the Ohio police officers who shot and killed Jayland Walker, a black man in Akron, have been cleared of wrongdoing. Police responded to the area following a report of someone with a gun. Officers identified Walker and, after they shouted commands, he turned and pointed a gun at them, leading to the shooting. Body camera footage of the incident was shared with the public, and the Summit County prosecutor has cleared the officers, stating that they acted justifiedly in the incident.
- Miranda rights and deportation proceedings
- Ninth Circuit Court and civil immigration arrests
- Jose Maria Zuniga De La Cruz appeal rejected
- Salvador Mendoza opinion on Miranda rights in deportation context
- Daniel Bress opinion on new versions of Miranda rights in immigration context
- Ohio police officers cleared in shooting of black man
- Jayland Walker shooting in Akron
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Exceptions to Miranda
Exceptions to Miranda | U.S. Constitution Annotated | US Law