Editing Miranda warning (section)

===State constitutional challenges===
Every state constitution has articles and provision guaranteeing individual rights.<ref name="Latzer1">{{Citation
|last1=Latzer
|first1=Barry
|author1-link=Barry Latzer
|publication-date=1991
|title=State Constitutions and Criminal Justice
|year=1991
|publisher=Greenwood Press
|publication-place=New York, U.S.A.
|language=en
|isbn=9780313261121
|oclc=23649129
|url=https://books.google.com/books?id=t-SRAAAAMAAJ
|access-date=2020-12-04
}}</ref> In most cases the subject matter is similar to the federal bill of rights.<ref name="Latzer1" />{{rp|2}}{{refn|group="Note"|This similarity is hardly surprising since the federal constitution and many state constitutions had common sources the state constitutions of some of the more important states such as Virginia.}} Most state courts interpretation of their constitution is consistent with the interpretation federal court's of analogous provisions of the federal constitution. With regard to ''Miranda'' issues, state courts have exhibited significant resistance to incorporating into their state jurisprudence some of the limitations on the ''Miranda'' rule that have been created by the federal courts.<ref name="Latzer1" />{{rp|89–91}} As a consequence a defendant may be able to circumvent the federal limitation on the ''Miranda'' rule and successfully challenge the admissibility under state constitutional provisions. Practically every aspect of the ''Miranda'' rule has drawn state court criticism. However the primary point of contention involve the following limitations on the scope of the ''Miranda'' rule: (1) the ''Harris'' exception{{refn|group="Note"|In ''Harris'' the United States Supreme Court allowed a ''Miranda''-defective statement to be used to impeach the trial testimony of a defendant. Note the ''Harris'' rule does not permit the use of a statement that fails to meet the voluntariness standards of the due process clause to be used for any purpose. The basis for the distinction is that a ''Miranda''-defective statement does not raise the questions of unreliability as does an involuntary statement.}} (2) the ''Burbine'' rule{{refn|group="Note"|In ''Moran v. Burbine'', 475 U.S. 412 (1986) the Court held that officers are not required to tell a suspect in custody that third parties had retained an attorney for the suspect. The failure of the police to inform the suspect of this fact did not render the waiver involuntary. ''Burbine'' decision was not well-received by the state courts. Six states specifically rejected the Burbine rule.}} and (3) the ''Fare'' rule.<ref name="Latzer1" />{{rp|91–98}}{{refn|group="Note"|The specific holding in Fare was that a juvenile's request to have his probation officer present during an interrogation was not an invocation of the juvenile's right to counsel. The Supreme Court stated that juveniles were essentially to be treated the same as adults for the purposes of Miranda. Many states adopted special rules concerning police interrogation of juveniles.}}