The Fifth Amendment provision, stating that no person shall be compelled in any criminal case to be a witness against himself, formed the basis of the Supreme Court's decision in Miranda v. Arizona. In 1966, the Supreme Court decided Miranda v. Arizona which determined the admissibility of suspects incriminating statements. For a statement to be admissible under Miranda, it has to be both voluntary and prefaced by complete Miranda warnings that are voluntarily waived. In 1997, Dickerson, a robbery suspect, in Virginia claimed to have confessed to a bank robbery prior to receiving his Miranda warnings. In court arguments, the district court judge suppressed the confession which was than appealed to the U.S. Court of Appeals for the Fourth Circuit. In the year 2000, the U.S. Supreme Court issued an opinion on the 1997 case of Dickerson. The Court held that Miranda is a Constitutional decision and therefore could not be overruled by an Act of Congress. Miranda was affirmed and declared a Constitutional Rule. This decision elevated the warning requirements of Miranda to constitutional proportions. The most significant and practical impact was the potential civil liability of individual law enforcement officers and their departments. The Dickerson decision did not alter the requirements Miranda placed on law enforcement. However, it established liability exposure to law enforcement officers and departments for failure to comply with those requirements. It was recommended that law enforcement managers re-evaluate their existing training and policies that address the practices of their personnel conducting interviews and interrogations.