Wainwright v. Greenfield

Wainwright v. Greenfield, 474 U.S. 284 (1986), is a case in which the United States Supreme Court reversed the lower court's finding and overturned the petitioner's conviction, on the grounds that it was fundamentally unfair for the prosecutor to comment during the court proceedings on the petitioner's silence invoked as a result of a Miranda warning.^[1]

Background

After his arrest in Florida for sexual battery, Greenfield was given three separate Miranda warnings. Each time, he exercised his right to remain silent and requested to speak with an attorney before answering questions. At his trial in the Circuit Court for Sarasota County, the respondent pleaded not guilty by reason of insanity. During closing arguments in the Florida trial court, the prosecutor reviewed the police officer's testimony, over defense counsel's objection, arguing that Greenfield's silence after receiving Miranda warnings was evidence of his sanity. The testimony described the occasions when respondent had exercised his right to remain silent. The prosecutor suggested that respondent's repeated refusals to answer questions without first consulting an attorney "demonstrated a degree of comprehension that was inconsistent with his claim of insanity".^[2]

Greenfield then unsuccessfully sought habeas corpus relief in Federal District Court, by suing the Florida Department of Corrections and its secretary, Louie L. Wainwright, arguing that the prosecutor's use of his silence violated the Due Process Clause of the Fourteenth Amendment as construed in Doyle v. Ohio (1976).^[2] The court affirmed the conviction, holding that the general rule precluding a prosecutor from commenting on a defendant's exercise of his right to remain silent did not apply to a case in which an insanity plea was filed.^[2]

Decision

The Court held that the prosecutor's use of respondent's post-arrest, post-Miranda warnings silence as evidence of sanity violated the Due Process Clause of the Fourteenth Amendment.^[2]

See also

• List of United States Supreme Court cases, volume 474

Footnotes

Further reading

• Matz, A. L. (1985). "The Sounds of Silence: Post-Miranda Silence and the Inference of Sanity". Boston University Law Review. 65: 1025. ISSN 0006-8047. 
• McHugh, M. C. (1985). "Greenfield v. Wainwright: The Use of Post-Miranda Silence to Rebut the Insanity Defense". American University Law Review. 35: 221. ISSN 0003-1453.