Which case holds that a Miranda waiver can be inferred from actions rather than an explicit written waiver?

• A. Miranda v Arizona
• B. North Carolina v Butler
• C. Berghuis v Thompkins
• D. Caldwell v State

Answer: (B)

The idea being tested is that a Miranda waiver can be inferred from a suspect’s actions, not only from a written or explicit verbal waiver. North Carolina v. Butler holds that after a suspect is properly advised of rights, a knowing and voluntary waiver can be shown through conduct and words indicating a willingness to discuss the case, even if there isn’t a formal written waiver. If the person continues talking or answering questions and doesn’t clearly request counsel, the court may find an implied waiver based on the total circumstances and the voluntary nature of the decision.

This distinguishes the decision from others that focus on different aspects: Miranda v. Arizona established that suspects must be warned about their rights; Berghuis v. Thompkins addressed whether silence after warnings can constitute or negate a waiver (and generally held that mere silence isn’t a waiver); Caldwell v. State involves different issues not central to implied waivers from conduct.