State of Arizona v. Pete J Vanwinkle

Summary

The court held that using a defendant's post-custody, pre-Miranda silence as evidence of guilt, including prosecutorial comment on that silence, violates the constitutional right to remain silent even when the silence follows a civilian accusation rather than police interrogation. The court nevertheless affirmed the convictions and sentences because the error was harmless beyond a reasonable doubt in light of the substantial independent evidence of guilt. The court vacated the court of appeals' decision while affirming the judgment below.