Cassell was then a professor at the University of Utah law school; he was later appointed to, and subsequently resigned from, a federal district court judgeship in that state.

In 1968, two years after the Miranda decision, Congress passed a law that purported to overrule it as part of the Omnibus Crime Control and Safe Streets Act of 1968.

§ 3501,[3] directed federal trial judges to admit statements of criminal defendants if they were made voluntarily, without regard to whether they had received the Miranda warnings.

Chief Justice Rehnquist wrote the majority opinion, and began by briefly describing the historical backdrop against which the Miranda ruling had emerged.

However, as time went on, the Supreme Court recognized that the Fifth Amendment was an independent source of protection for statements made by criminal defendants in the course of police interrogation.

"In Miranda, we noted that the advent of modern custodial police interrogation brought with it an increased concern about confessions obtained by coercion."

Custodial police interrogation by its very nature "isolates and pressures the individual" so that he might eventually be worn down and confess to crimes he did not commit in order to end the ordeal.

He disputed the notion that Miranda was a constitutional rule, pointing to several cases in which the Court had declined to exclude evidence despite the absence of warnings.