Rhode Island v. Innis, 446 U.S. 291 (1980), is a decision by the United States Supreme Court that clarifies what constitutes "interrogation" for the purposes of Miranda warnings.

As the officers searched for the weapon, Innis was again read his Miranda rights, to which he acknowledged understanding but nonetheless was concerned for the children in the area.

The court held that the Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent.

There is nothing to suggest that the officers were aware that respondent was peculiarly susceptible to an appeal to his conscience concerning the safety of handicapped children.

However, in Brewer, the state had already initiated formal judicial proceedings by obtaining an arrest warrant and arraigning Williams, thus triggering the protections of the Sixth Amendment right to counsel under the Massiah doctrine.