I'm looking for comparisons in the United States Miranda rights and England's rights when arrested.?

Question

I saw in the movie Hot Fuzz that he arrested someone, and he said something like "you have the right to" and then his mic faded out. What are the differences/similarities between the United States and England?

Answer 1

In the UK, the right to silence has a long history in England and Wales, first having been codified in the Judges' Rules in 1912.

A defendant in a criminal trial has a choice whether or not to give evidence in the proceedings. Further, there is no general duty to assist the police with their inquiries.

At common law, and particularly following the passing of the Criminal Justice and Public Order Act 1994 adverse inferences may be drawn in certain circumstances where the accused:

~fails to mention any fact which he later relies upon and which in the circumstances at the time the accused could reasonably be expected to mention;

~fails to give evidence at trial or answer any question;
fails to account on arrest for objects, substances or marks on his person, clothing or footwear, in his possession, or in the place where he is arrested; or

~fails to account on arrest for his presence at a place.

There may be no conviction based wholly on silence.

Where inferences may be drawn from silence, the court must direct the jury as to the limits to the interferences which may properly be drawn from silence

Answer 2

They are fairly even now. In the UK, you can still stay silent, but that silence can be interpretted any way they like by the jury. That change was made about 10 years ago - previously, staying silent could not be taken to mean anything.

In the US, all interviewing must stop when a suspect asks for a lawyer; in the UK, there is some leeway allowed.

There are other marginal differences, but generally the systems are aligned.