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Back to the Basics: A Fail-Safe Method for Administering the Miranda Warnings after Duckworth v. Eagan

Abstract

This Note analyzes the potential impact of the Duckworth opinion upon the future of the Miranda warnings. Focusing on their precise wording, the issue presented is whether the warnings adequately convey fifth amendment rights to the accused. First, a brief history of the Miranda decision establishes the original purpose the Court intended the warnings to serve. Second, the controversy emanating from various circuit courts demonstrates the sharp division of authority regarding the formula required to satisfy the mandates of Miranda. Third, a review of a related Supreme Court opinion and subsequent interpreting district court decisions proves the necessity of instruction from the Supreme Court to resolve which version of the warnings complies with Miranda. Finally, an analysis of Duckworth and its impact upon Miranda assesses the probable future status of the warnings.

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32 Ariz. L. Rev. 645 (1990)

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