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Pennsylvania v. Muniz | 496 U.S. 582, 110 S. Ct. 2638, 110 L. Ed. 2d 528 (1990)

Generally, a defendant’s responses to questions asked before receiving Miranda warnings are inadmissible. But what about neutral, biographical questions asked to process an arrest? The Supreme Court addressed the Fifth Amendment’s limits in Pennsylvania versus Muniz.

After Inocencio Muniz was pulled over and failed three sobriety tests, he was arrested for driving while intoxicated.

Muniz was taken to a booking center and informed he was being videotaped. After slurring and stumbling over responses to questions including his age, address, and height, officers asked Muniz the date of his sixth birthday, which he didn’t know. Officers then had Muniz repeat the sobriety tests. Muniz frequently asked for clarification and explained why he was struggling. After failing the tests and refusing a breathalyzer, an officer read Muniz his Miranda rights.

At trial, the videotape was admitted into evidence, and Muniz was convicted. On appeal, the Pennsylvania Superior Court reversed Muniz’s conviction. The Supreme Court granted cert.

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