Mapp v. Ohio applies to the States the exclusionary rule which requires that no illegally obtained evidence can be used in a trial. Escobedo v. Illinois mandates the right to counsel for an arrestee during the investigative phase of the case. Miranda v. Arizona requires police to inform arrestees of their right against self-incrimination which includes the right not to answer police questions and to have immediate assistance of counsel. A review of the literature on these decisions reveals sound constitutional bases for the Court's rulings. Although critics have argued that Miranda has no constitutional basis because of its enunciated warnings, a review of the U.S. Supreme Court's history shows that the court has at times enunciated rules for lower courts and other bodies to protect constitutional rights. Although Miranda is typically criticized by conservatives, the right against self-incrimination is often used to the fullest by conservative political figures (Oliver North, for example) when they are charged by the State. Still, in the 30 U.S. Supreme Court cases involving Miranda procedures since Earl Warren left the bench, law enforcement has prevailed in 25 cases. Conservative perceptions that street criminals benefit from Miranda have undermined Miranda's intent. 3 notes and 35-item bibliography