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Supreme Court· 6/29/1981

California v. Prysock

Citations

  • 453 U.S. 355
  • 101 S. Ct. 2806
  • 69 L. Ed. 2d 696
  • 1981 U.S. LEXIS 131
  • 49 U.S.L.W. 3964

About this case

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From Wikipedia, the free encyclopedia

1981 United States Supreme Court case

California v. Prysock, 453 U.S. 355 (1981) was a per curiam United States Supreme Court case where the Court ruled that as long as the message of a Miranda warning was adequately communicated, it does not need to be precisely phrased.

Background

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On January 30, 1978, Donna Iris Erickson was found brutally murdered in Tulare County, California . Later, Randall James Prysock and a codefendant were arrested for committing the murder. As Prysock was 16 years old at the time,[1] Tulare County Sheriff's Sergeant Byrd informed him of his Miranda rights, and notified his parents after he initially refused to answer questions. After his parents arrived, Prysock changed his mind and decided to answer Sergeant Byrd's questions on tape. Byrd then reiterated Prysock's rights under Miranda and as a juvenile. He stated that Prysock had the right to have counsel and his parents present before and during questioning, but was not explicitly told that he could request an attorney before further questioning. Byrd then had a conversation with Prysock's mother where she chose not to hire a lawyer.

During Prysock's trial, his motion to suppress the statements was rejected, and he was convicted of first-degree murder. The California Court of Appeal, Fifth District reversed and remanded his conviction on the basis that "the rigidity of the Miranda rules and the way in which they are to be applied was conceived of and continues to be recognized as the decision's greatest strength."

Decision

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In a 6-3 per curiam decision, the Court ruled that Prysock's rights were adequately conveyed and that _Miranda v. Arizona _ did not require a "talismanic incantation."[2]

In a dissent authored by Justice John P. Stevens , he argued that Sergeant Byrd left out crucial information that Prysock had the right to the services of an attorney regardless of his parents' willingness to hire one. Instead, the phrasing of "[the] right to have a lawyer appointed to represent you at no cost to yourself" could be construed as having the right to an attorney at trial. The statement about parents being present inserted between the rights to an attorney during questioning, and the untaped conversation with Prysock's mother further muddled the waters. The ambiguous meaning thus undercuts _Miranda'_s message of "meaningful advice to the unlettered and unlearned in language which he can comprehend and on which he can knowingly act."[3]

References

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  1. ↑ PEOPLE v. PRYSOCK (1982) Findlaw
  2. ↑ California v. Prysock, 453 U.S. 355 (1981) Justia
  3. ↑ Coyote v. United States, 380 F.2d 305, 308 (CA10 1967), cert. denied, 389 U.S. 992.

External links

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How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • holding that warnings were adequate since the defendant “was told of his right to have a lawyer present prior to and during interrogation, and his right to have a lawyer appointed at no cost if he could not afford one”
  • remarking that Miranda itself indicated that no talismanic incantation was required to satisfy its strictures
  • holding that the warnings given were adequate under Miranda since the defendant “was told of his right to have a lawyer present prior to and during interrogation, and his right to have a lawyer appointed at no cost if he could not afford one.”
  • stating that Miranda does not require a \talismanic incantation\ of the warnings, but rather only the fully effective equivalent of such warnings
  • explaining that verbatim incantation of Miranda warnings was not required by the case itself, nor necessary to serve the purposes underlying Miranda warnings
  • remarking that “Miranda itself indicated that no talismanic incantation was required to satisfy its strictures”

Source: CourtListener parenthetical corpus (CC0).

Judges: Stevens, Brennan, Marshall

Read full opinion on CourtListener

Cited by

298 cases in this archive cite this case; the 20 most cited are listed.

Cites

12 cases in this archive are cited by this case.

Other cases named California v. Prysock

1 other CourtListener record shares this case name.

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This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.