Duhaime's Law Dictionary


Doyle Rule Definition:

(USA) A rule of criminal process that the use for impeachment purposes of a defendant's silence, at the time of arrest and after receiving Miranda warnings, violates the Due Process Clause of the Fourteenth Amendment.

Related Terms: Miranda Warning, Fourteenth Amendment

Named after the 1976 United States Supreme Court decision, Doyle v Ohio,  which postulated the rule of criminal law.

The rule was stated as follows in Hill v Turpin (1998):

"In Doyle v. Ohio, the Supreme Court held that the use for impeachment purposes of a defendant's silence, at the time of arrest and after receiving Miranda warnings, violates the Due Process Clause of the Fourteenth Amendment. As the Court has recognized in numerous post-Doyle opinions, the Doyle rule rests on the fundamental unfairness of implicitly assuring a suspect that his silence will not be used against him and then using his silence to impeach an explanation subsequently offered at trial. The source of this implicit assurance is the giving of Miranda warnings, through which a person taken into custody is expressly advised that he has the right to remain silent, and that he has a right to retained or appointed counsel before submitting to interrogation. Thus, although the improper references at issue in Doyle concerned only the defendants' post-Miranda silence, the prohibition extends equally to impeachment use of a 808*808 defendant's post-Miranda invocation of the right to counsel."

REFERENCES:

  • Doyle v Ohio, 426 US 610 (1976)
  • Hill v. Turpin, 135 F.3d 1411
  • Qureshi v. State, 662 SE 2d 806 (Court of Appeals of Georgia, 2008)

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