Dickerson v. United States, 530 U.S. 428 (2000), upheld the requirement that the Miranda warning be read to criminal suspects and struck down a federal statute that purported to overrule Miranda v. Arizona (1966). Dickerson is regarded as a significant example of a rare departure by the Court from the principle of party presentation. The Court noted that neither party in the case advocated on behalf of the constitutionality of 18 U.S.C. § 3501, the specific statute at issue in the case. Accordingly, it invited Paul Cassell, a former law clerk to Antonin Scalia and Warren E. Burger, to argue that perspective. 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. Background In Miranda v. Arizona, the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by police may not be admitted in court unless the suspect first had certain warnings read to them beforehand. By now, these warnings are familiar to most Americans: that the suspect has the right to remain silent during the interrogation, that anything they say to the police may be used against them in a court of law, that they have the right to legal counsel, and that if they cannot afford legal counsel a lawyer will be provided for them. 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. This statute, 18 U.S.C. § 3501, 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. Under § 3501, voluntariness depended on such things as (1) the time between arrest and arraignment, (2) whether the defendant knew the crime for which they had been arrested, (3) whether they had been told that they did not have to talk to the police and that any statement could be used against them, (4) whether the defendant knew prior to questioning that they had the right to the assistance of counsel, and (5) whether they actually had the assistance of counsel during questioning. However, the "presence or absence of any of" these factors "need not be conclusive on the issue of voluntariness of