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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.)

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