the confession." Because § 3501 was an act of Congress, it applied only to federal criminal proceedings and criminal proceedings in the District of Columbia. Charles Dickerson had been arrested for bank robbery and for using a firearm during a crime of violence, both federal crimes. He moved to suppress statements he made to the FBI because he had not received the Miranda warnings before he spoke to the FBI. The district court suppressed the statements, and so the government appealed. The Fourth Circuit reversed the district court, reasoning that § 3501 had supplanted the requirement that the police give the Miranda warnings because Miranda was not a constitutional requirement and therefore Congress could overrule that decision by legislation. The Supreme Court then agreed to hear the case. Opinion of the Court Chief Justice Rehnquist wrote the majority opinion, and began by briefly describing the historical backdrop against which the Miranda ruling had emerged. A suspect's confession had always been inadmissible if it had been the result of coercion or otherwise given involuntarily. This was true in England, from where American law inherited that rule. 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. In Miranda, the Court had adopted the now-famous four warnings to protect against this particular evil. Congress, in response, enacted § 3501. That statute clearly was designed to overrule Miranda because it expressly focused solely on voluntariness of the confession as a touchstone for admissibility. Did Congress have the authority to pass such a law? On the one hand, the Court's power to craft nonconstitutional supervisory rules over the federal courts exists only in the absence of a specific statute passed by Congress. However, if on the other hand the Miranda rule was constitutional, Congress could not overrule it, because the Court alone is the final arbiter of what the Constitution requires. As evidence of the fact that the Miranda rule was constitutional in nature, the Court