Doyle v. Ohio
United States Supreme Court
426 U.S. 610 (1976)
At the trials of Jefferson Doyle and Richard Wood (defendants), evidence showed that William Bonnell, acting as a narcotics informant, told law enforcement agents that he needed $1,750 for a drug transaction that he set up with Doyle and Wood. The agents surveilled Bonnell while he met with Doyle and Wood in a bar. Bonnell and Wood then drove in Bonnell’s truck to a parking lot in another town where Bonnell and Wood waited for Doyle to get the marijuana. After Doyle arrived the transaction proceeded, observed by law enforcement agents, and then Bonnell left the parking lot. Since the agents had given Bonnell $1,320 in cash, Doyle and Wood realized they had been shortchanged and were driving around looking for Bonnell when they were pulled over and arrested by agent Kenneth Beamer who gave them Miranda warnings. The $1,320 in cash was found in the car. At trial, Doyle and Wood challenged the agents’ observation of the transaction and asserted that Bonnell framed Doyle and Wood, claiming Bonnell was supposed to sell the marijuana to Doyle and Wood but the deal fell through because Bonnell got angry, threw the cash in the car and left with the marijuana. Doyle and Wood claimed they were driving around to find Bonnell and ask what the money was for. On cross examination of Wood at his trial, the court allowed the prosecutor for the State of Ohio (plaintiff) to ask Wood whether Wood told agent Beamer the defense’s version of events when Wood was being arrested by Beamer. Wood admitted that he had not told agent Beamer. Doyle and Wood were convicted and the Ohio courts affirmed on appeal. Doyle and Wood appealed to the United States Supreme Court. The State admitted that use of post-arrest silence was not admissible as substantive evidence of guilt, but asserted that it was necessary for the limited purpose of impeachment to show that a defendant had changed his story.
Rule of Law
Holding and Reasoning (Powell, J.)
Dissent (Powell, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 166,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.