Not only have the Miranda warnings become a recognized procedure in police interrogations in the United States, but they have been adopted or strengthened over the years in formerly inquisitorial countries like Germany, Italy, Spain and most recently France, and are now recognized as having constitutional status. This article discusses the protections afforded to criminal suspects and defendants overseas when faced with interrogation by police, prosecutors, investigating magistrates or judges of the investigation. It compares the admonitions given to such suspects with those provided in the Miranda decision and discusses their constitutional, or statutory status. It further discusses when such admonitions must be given, to what extent the police or other officials may re-admonish after the right to silence or counsel has been invoked, and whether statements taken in violation of such admonitions or the fruits thereof may be used in court, or for the purpose of conducting further investigations or prosecuting third parties. This article also assesses what we can learn from a comparison of U.S. law with that of other democratic countries with systems derived from the inquisitorial model. The comparison focuses primarily on England, France, Germany, Italy, Russia, and Spain.
Thaman, Stephen C., Miranda in Comparative Law (2001). St. Louis University Law Journal, Vol. 45, No. 2, p. 581, 2001.