Dickerson (defendant) was indicted for bank robbery. Dickerson moved to have statements he made during an FBI interrogation suppressed, claiming he never received proper Miranda warnings. The trial court found that Dickerson had not in fact received proper Miranda warnings. However, two years after Miranda
v. Arizona, 384 U.S. 436 (1966) was decided, Congress passed 18 U.S.C. § 3501, which permits statements made by a suspect during a custodial police interrogation to be admitted at trial as long as they were made voluntarily. The trial court held that Miranda was not a constitutional holding, and Congress therefore had the authority to effectively overrule Miranda with a statute. The court of appeals agreed, holding that the protections put forth in Miranda are not constitutionally required.