Live Demo
June 13, 1966 — U.S. Supreme Court

The confession — was it legal?

Miranda is settled law. But 23 exceptions later, citing it without precision is how suppression motions fail.

MikeCheck found the misapplication in under a second.

0.6s
Analysis time
58 yr
Precedent age
14
Limitations found
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01 — Analysis

Real-time citation scanning

MikeCheck reads your suppression motion, extracts every citation, and runs each one against live legal databases — detecting misapplication before opposing counsel does.

Superior Court of the State of Arizona
In and For the County of Maricopa
Defendant's Motion to Suppress Statements
Case No. CR-2024-008847
I. INTRODUCTION
Defendant respectfully moves to suppress all statements obtained by officers who failed to comply with the requirements of Miranda v. Arizona, 384 U.S. 436 (1966) before conducting a custodial interrogation.
II. ARGUMENT
A. MIRANDA WARNINGS WERE CONSTITUTIONALLY REQUIRED.
As confirmed in Dickerson v. United States, 530 U.S. 428 (2000), Miranda is a constitutional rule that Congress cannot legislatively override. The right to counsel established in Edwards v. Arizona, 451 U.S. 477 (1981) required officers to halt questioning the moment Defendant invoked.
B. EXCEPTIONS DO NOT APPLY HERE.
The public safety exception of New York v. Quarles, 467 U.S. 649 (1984) does not apply absent an immediate threat. Furthermore, Defendant's continued silence adequately invoked Miranda protections. See Berghuis v. Thompkins, 560 U.S. 370 (2010). Defendant has a federal civil rights remedy for this Miranda violation. See Vega v. Tekoh, 596 U.S. 543 (2022).
Waiting
0.0s
1 Extracting citations
2 Resolving reporters
3 Checking validity
4 Analyzing treatment
5 Detecting misapplication
6 Generating report
Risk Level
ATTENTION
2 citations misapplied or narrowed
1Misapplied
1Narrowed
3Good law
1Warning
02 — Findings

What MikeCheck found

6
Citations analyzed
1
Misapplied
1
Narrowed
3
Good law
⚡ 0.6s
⚠ Requires immediate attention
Vega v. Tekoh
● Misapplied
596 U.S. 543 (2022) · Supreme Court
⚠ Brief cites Vega for a §1983 civil rights remedy — Vega held the OPPOSITE: Miranda violations do not give rise to §1983 damages claims.
misapplied opposite holding §1983 foreclosed no civil remedy
96% confidence
WHY THIS MATTERS
Vega resolved a circuit split by holding Miranda is a prophylactic rule, not a constitutional right — it does not give rise to §1983 civil damages. The brief's §1983 theory requires a constitutional violation; Vega forecloses it. Remedy for a Miranda violation is suppression of the confession, not civil relief.
RECOMMENDED ACTION
Remove the §1983 civil damages theory. Identify a distinct Fourth or Fifth Amendment violation that independently supports §1983. If none exists, the suppression motion is the only available remedy.
⚡ Narrowed — review required
Berghuis v. Thompkins
⚡ Narrowed
560 U.S. 370 (2010) · Supreme Court
⚡ Brief claims silence invokes Miranda — Berghuis requires explicit, unambiguous invocation. Silence alone is insufficient.
narrows explicit invocation required silence insufficient
91% confidence
WHY THIS MATTERS
The brief argues silence invoked Miranda rights. Berghuis held that invoking the right to remain silent requires an unambiguous, affirmative statement — silence alone is insufficient. Thompkins impliedly waived his rights by speaking after 3 hours of non-custodial interrogation. This directly undermines the suppression argument.
RECOMMENDED ACTION
Locate specific language in which the client unambiguously invoked Miranda: "I want to remain silent," "I'm done talking," or equivalent. If none exists, argue involuntariness under a totality-of-circumstances analysis instead.
✓ 3 citations confirmed as good law · 1 requires caveat review
✓ Good law
Miranda v. Arizona
✓ Good Law
384 U.S. 436 (1966) · Supreme Court
foundational holding followed 14 carve-outs since 1966
98% confidence
WHY IT'S SAFE
58 years of unbroken precedent with 14 categorical carve-outs but no overruling. Dickerson (2000) reaffirmed Miranda as a constitutional rule that Congress cannot abrogate by statute, defeating 18 U.S.C. §3501. As of 2024, Miranda is foundational law.
HOW TO USE IT
Cite Miranda for the warnings requirement and the presumption of inadmissibility. Pair with Dickerson to reinforce the constitutional — not merely prophylactic — status of the rule.
Dickerson v. United States
✓ Good Law
530 U.S. 428 (2000) · Supreme Court
reaffirmed constitutional rule 18 U.S.C. §3501 defeated
99% confidence
WHY IT'S SAFE
Chief Justice Rehnquist, no fan of Miranda, wrote the Dickerson majority: once the Court establishes a constitutional rule, only the Court can overrule it. §3501's attempt to make voluntariness the only test was unconstitutional.
HOW TO USE IT
Cite when opposing counsel argues Congress can modify the Miranda regime. Dickerson closes that door.
New York v. Quarles
✓ Good Law
467 U.S. 649 (1984) · Supreme Court
public safety exception followed correctly cited
97% confidence
WHY IT'S SAFE
The public safety exception permits questions reasonably prompted by an immediate safety concern before Miranda warnings. The weapon location question falls squarely within Quarles's narrow exception. Consistently followed for 40 years.
HOW TO USE IT
Cite Quarles for the public safety exception — but only for the specific emergency question. Do not extend it to general pre-warning questioning.
⚠ Good law with caveat
Edwards v. Arizona
⚠ Qualified
451 U.S. 477 (1981) · Supreme Court
⚡ Right to counsel is solid — but see Maryland v. Shatzer (2010): a 14-day break in custody resets the Edwards protection.
followed right to counsel ⚡ shatzer caveat 14-day break rule
94% confidence
WHY THIS MATTERS
Edwards is solid — but Maryland v. Shatzer (2010) created a 14-day reset rule: if a suspect is released from custody for 14+ days before re-interrogation, the Edwards protections do not apply to the second interrogation.
RECOMMENDED ACTION
Verify the custody timeline. If there was a 14+ day break in custody, Edwards does not bar re-initiation. Cite both Edwards and Shatzer whenever custody continuity is at issue.
03 — Citation Network

The Miranda web

58 years of refinement, limitation, and one dramatic reaffirmation. MikeCheck maps the full citation network — showing which nodes strengthen Miranda and which have chipped away at it.

Anchor (subject)
Reaffirms / Extends
Limits / Narrows
Forecloses remedy
Definitional
04 — Jurisdiction Intelligence

Eight circuits. One question.

What makes an interrogation "custodial"? Eight circuits. Eight answers. MikeCheck surfaces the split — and tells you which forum is most protective for your client.

8Circuits analyzed
EmergingSplit type
MediumSCOTUS review likelihood
"Custody" DefinitionIssue
← Strict protections (narrow exceptions) Permissive exceptions →
1st Cir.
72%
Strict
2nd Cir.
68%
Strict
4th Cir.
55%
Expanded
5th Cir.
80%
Permissive
6th Cir.
60%
Strict
9th Cir.
75%
Broad
10th Cir.
Mixed
D.C. Cir.
58%
Strict
SCOTUS Review Probability
Medium
An emerging 5th/9th Circuit split on the scope of custodial interrogation creates viable cert petition grounds as the conflict matures.
9th Circuit most protective for defense
05 — Quote Verification

Every word matters

A misquoted Miranda warning is more than a typo — it can undermine the constitutional foundation of your suppression argument. MikeCheck catches every deviation from the original text.

✗ As written in suppression motion
"...the person must be warned of the right to remain silent, that any statement may be used against him, and that he has the right to an attorney, either retained or appointed."
Miranda v. Arizona, 384 U.S. 436 (1966)
✓ Actual source text (384 U.S. at 479)
"...the person must be warned that he has a right to remain silent, that any statement he does make may be used as evidence against him, and that he has a right to the presence of an attorney, either retained or appointed."
Miranda v. Arizona, 384 U.S. 436, 479 (1966)
0%
Similarity score
Three deviations detected: article swap ("a" vs. "the"), omission of "he does make...as evidence," and omission of "the presence of" — legally significant physical presence of counsel.
06 — Treatment History

Fifty-eight years. Fourteen limitations.

Miranda survived — but Dickerson (2000) is the only upswing in 58 years. The case fought back once. Since 2000, the narrowing has continued.

Positive treatment
Negative treatment
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