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Miranda v. Arizona
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Miranda v. Arizona
Supreme Court of the United States
Decided June 13, 1966
Full case name
Miranda v. State of Arizona; Westover v. United States; Vignera v. State of New York; State of California v. Stewart
Citations
384 U.S. 436 (more)
86 S. Ct. 1602; 16 L. Ed. 2d 694; 1966 U.S. LEXIS 2817; 10 A.L.R.3d 974
Argument
Oral argument
Prior history
Defendant . Superior Ct.; affirmed, 401 P.2d 721 (Ariz. 1965); cert. granted, 382 U.S. 925 (1965)
Subsequent history
Retrial on remand, defendant convicted, Ariz. Superior Ct.; affirmed, 450 P.2d 364 (Ariz. 1969); rehearing denied, Ariz. Supreme Ct. March 11, 1969; cert. denied, 396 U.S. 868 (1969)
Holding
The Fifth Amendment right against self-incrimination requires law enforcement officials to advise a suspect interrogated in custody of his or her rights to remain silent and to obtain an attorney. Supreme Court of Arizona reversed and remanded.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · William O. Douglas
Tom C. Clark · John M. Harlan II
William J. Brennan Jr. · Potter Stewart
Byron White · Abe Fortas
Case opinions
Majority
Warren, joined by Black, Douglas, Brennan, Fortas
Concur/dissent
Clark
Dissent
Harlan, joined by Stewart, White
Dissent
White, joined by Harlan, Stewart
Laws applied
U.S. Const. amends. V, XIV
Miranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the United States Supreme Court. In a 5–4 majority, the Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant was informed of the right to consult with an attorney before and during questioning and of the right against self-incrimination before police questioning, and that the defendant not only understood these rights, but voluntarily waived them.
This case has a significant impact on law enforcement in the United States, by making what became known as the Miranda rights part of routine police procedure to ensure that suspects were informed of their rights. The Supreme Court decided Miranda with three other consolidated cases: Westover v. United States, Vignera v. New York, and California v. Stewart.
The Miranda warning (often shortened to "Miranda", or "Mirandizing" a suspect) is the name of the formal warning that is required to be given by law enforcement in the United States to criminal suspects in police custody (or in a custodial situation) before they are interrogated, in accordance with the Miranda ruling. Its purpose is to ensure the accused are aware of, and reminded of, these rights before questioning or actions that are reasonably likely to elicit an incriminating response.
Per the U.S. Supreme Court decision Berghuis v. Thompkins (June 1, 2010), criminal suspects who are aware of their right to silence and to an attorney, but choose not to "unambiguously" invoke them, may find any subsequent voluntary statements treated as an implied waiver of their rights, and used as or as part of evidence. At least one scholar has argued that Thompkins effectively gutted Miranda.[1]
Contents
[hide]
1 Background
1.1 Legal aid movement
1.2 Arrest and conviction
2 Opinion of the Supreme Court
2.1 Clark's concurrence in part, dissent in part
2.2 Harlan's dissent
2.3 White's dissent
3 Subsequent developments
3.1 Retrial
3.2 Reaction
3.3 Miranda warning
3.4 Legal developments
4 See also
5 References
6 Further reading
7 External links
Background[edit]
Legal aid movement[edit]
During the 1960s, a movement which provided defendants with legal aid emerged from the collective efforts of various bar associations.
In the civil realm, it led to the creation of the Legal Services Corporation under the Great Society program of President Lyndon Baines Johnson. Escobedo v. Illinois, a case which closely foreshadowed Miranda, provided for the presence of counsel during police interrogation. This concept extended to a concern over police interrogation practices, which were considered by many[who?] to be barbaric and unjust. Coercive interrogation tactics were known in period slang as the "third degree".[citation needed]
Arrest and conviction[edit]
On March 13, 1963, Ernesto Miranda was arrested, by the Phoenix Police Department, based on circumstantial evidence linking him to the kidnapping and rape of an eighteen-year-old woman ten days earlier.[2] After two hours of interrogation by police officers, Miranda signed a confession to the rape charge on forms that included the typed statement: "I do hereby swear that I make this statement voluntarily and of my own free will, with no threats, coercion, or promises of immunity, and with full knowledge of my legal rights, understanding any statement I make may be used against me."[3]
However, at no time was Miranda told of his right to counsel. Before being presented with the form on which he was asked to write out the confession he had already given orally, he was not advised of his right to remain silent, nor was he informed that his statements during the interrogation would be used against him. At trial, when prosecutors offered Miranda's written confession as evidence, his court-appointed lawyer, Alvin Moore, objected that because of these facts, the confession was not truly voluntary and should be excluded. Moore's objection was overruled and based on this confession and other evidence, Miranda was convicted of rape and kidnapping. He was sentenced to 20–30 years of imprisonment on each charge, with sentences to run concurrently. Moore filed Miranda's appeal to the Arizona Supreme Court, claiming that Miranda's confession was not fully voluntary and should not have been admitted into the court proceedings. The Arizona Supreme Court affirmed the trial court's decision to admit the confession in State v. Miranda, 401 P.2d 721 (Ariz. 1965). In affirmation, the Arizona Supreme emphasized heavily the fact that Miranda did not specifically request an attorney.[4]
Attorney John Paul Frank, former law clerk to Justice Hugo Black, represented Miranda in his appeal to the U.S. Supreme Court.[5]
Opinion of the Supreme Court[edit]
Chief Justice Earl Warren, a former prosecutor, delivered the opinion of the Court[6], ruling that due to the coercive nature of the custodial interrogation by police (Warren cited several police training manuals which had not been provided in the arguments), no confession could be admissible under the Fifth Amendment self-incrimination clause and Sixth Amendment right to an attorney unless a suspect had been made aware of his rights and the suspect had then waived them:
The person in custody must, prior to interrogation, be clearly informed that he has the right to remain silent, and that anything he says will be used against him in court; he must be clearly informed that he has the right to consult with a lawyer and to have the lawyer with him during interrogation, and that, if he is indigent, a lawyer will be appointed to represent him.[7]
Thus, Miranda's conviction was overturned. The Court also made clear what had to happen if the suspect chose to exercise his or her rights:
If the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease... If the individual states that he wants an attorney, the interrogation must cease until an attorney is present. At that time, the individual must have an opportunity to confer with the attorney and to have him present during any subsequent questioning.
Justice Brennan's comments on the Miranda decision.
Warren pointed to the existing practice of the Federal Bureau of Investigation (FBI) and the rules of the Uniform Code of Military Justice, both of which required notifying a suspect of his right to remain silent; the FBI warning included notice of the right to counsel.
However, the dissenting justices accused the majority of overreacting to the problem of coercive interrogations, and anticipated a drastic effect. They believed that, once warned, suspects would always demand attorneys, and deny the police the ability to gain confessions.
Clark's concurrence in part, dissent in part[edit]
In a separate concurrence in part, dissent in part, Justice Tom C. Clark argued that the Warren Court went "too far too fast". Instead, Justice Clark would use the "totality of the circumstances" test enunciated by Justice Goldberg in Haynes v. Washington. Under this test, the court would:
consider in each case whether the police officer prior to custodial interrogation added the warning that the suspect might have counsel present at the interrogation and, further, that a court would appoint one at his request if he was too poor to employ counsel. In the absence of warnings, the burden would be on the State to prove that counsel was knowingly and intelligently waived or that in the totality of the circumstances, including the failure to give the necessary warnings, the confession was clearly voluntary.
Harlan's dissent[edit]
In dissent, Justice John Marshall Harlan II wrote that "nothing in the letter or the spirit of the Constitution or in the precedents squares with the heavy-handed and one-sided action that is so precipitously taken by the Court in the name of fulfilling its constitutional responsibilities". Harlan closed his remarks by quoting former Justice Robert H. Jackson: "This Court is forever adding new stories to the temples of constitutional law, and the temples have a way of collapsing when one story too many is added."
White's dissent[edit]
Justice Byron White took issue with the court announcing a new constitutional right when it had no "factual and textual bases" in the Constitution or previous opinions of the Court for the rule announced in the opinion. He stated: "The proposition that the privilege against self-incrimination forbids in-custody interrogation without the warnings specified in the majority opinion and without a clear waiver of counsel has no significant support in the history of the privilege or in the language of the Fifth Amendment." Nor did Justice White believe it had any basis in English common law.
White further warned of the dire consequences of the majority opinion:
I have no desire whatsoever to share the responsibility for any such impact on the present criminal process.
In some unknown number of cases, the Court's rule will return a killer, a rapist or other criminal to the streets and to the environment which produced him, to repeat his crime whenever it pleases him. As a consequence, there will not be a gain, but a loss, in human dignity.
Subsequent developments[edit]
Retrial[edit]
Miranda was retried in 1967 after the original case against him was thrown out. This time the prosecution, instead of using the confession, introduced other evidence and called witnesses. One witness was Twila Hoffman, a woman with whom Miranda was living at the time of the offense; she testified that he had told her of committing the crime.[8][9] Miranda was convicted in 1967 and sentenced to serve 20 to 30 years.[9] The Supreme Court of Arizona affirmed,[10] and the United States Supreme Court denied review.[11] Miranda was paroled in 1972. After his release, he returned to his old neighborhood and made a modest living autographing police officers' "Miranda cards" which contained the text of the warning, for reading to arrestees. He was stabbed to death during an argument in a bar on January 31, 1976.[12] A suspect was arrested, but he, unlike Miranda, exercised his right to remain silent. With no evidence against him, he was released.[13]
Another three defendants whose cases had been tied in with Miranda's – an armed robber, a stick-up man, and a bank robber – either made plea bargains to lesser charges or were found guilty again despite the exclusion of their confessions.[14]
Reaction[edit]
The Miranda decision was widely criticized when it came down, as many felt it was unfair to inform suspected criminals of their rights, as outlined in the decision. Richard Nixon and other conservatives denounced Miranda for undermining the efficiency of the police, and argued the ruling would contribute to an increase in crime. Nixon, upon becoming President, promised to appoint judges who would be "strict constructionists" and who would exercise judicial restraint. Many supporters of law enforcement were angered by the decision's negative view of police officers.[citation needed]
Miranda warning[edit]
Main article: Miranda warning
After the Miranda decision, the nation's police departments were required to inform arrested persons or suspects of their rights under the ruling prior to custodial interrogation.[15] Such information is called a Miranda warning. Since it is usually required that the suspects be asked if they understand their rights, courts have also ruled that any subsequent waiver of Miranda rights must be knowing, intelligent, and voluntary.[16]
Many American police departments have pre-printed Miranda waiver forms which a suspect must sign and date (after hearing and reading the warnings again) if an interrogation is to occur.[17][18]
Data from the FBI Uniform Crime Reports shows a sharp reduction in the clearance rate of violent and property crimes after Miranda.[19] However, according to other studies from the 1960s and 1970s, "contrary to popular belief, Miranda had little, if any, effect on detectives’ ability to solve crimes."[9]
Legal developments[edit]
The federal Omnibus Crime Control and Safe Streets Act of 1968 purported to overrule Miranda for federal criminal cases and restore the "totality of the circumstances" test that had prevailed previous to Miranda.[20] The validity of this provision of the law, which is still codified at 18 U.S.C. § 3501, was not ruled on for another 30 years because the Justice Department never attempted to rely on it to support the introduction of a confession into evidence at any criminal trial.[citation needed]
Miranda was undermined by several subsequent decisions which seemed to grant exceptions to the "Miranda warnings", challenging its claim to be a necessary corollary of the Fifth Amendment. The exceptions and developments that occurred over the years included:
The Court found in Harris v. New York, 401 U.S. 222 (1971), that a confession obtained in violation of the Miranda standards may nonetheless be used for purposes of impeaching the defendant's testimony: that is, if the defendant takes the stand at trial and the prosecution wishes to introduce the defendant's confession as a prior inconsistent statement to attack the defendant's credibility, the Miranda holding will not prohibit this.
The Court found in Rhode Island v. Innis, 446 U.S. 291 (1980), that a "spontaneous" statement made by a defendant while in custody, even though the defendant has not been given the Miranda warnings or has invoked the right to counsel and a lawyer is not yet present, is admissible in evidence, as long as the statement was not given in response to police questioning or other conduct by the police likely to produce an incriminating response.
The Court found in Berkemer v. McCarty, 468 U.S. 420 (1984), that a person subjected to custodial interrogation is entitled to the benefit of the procedural safeguards enunciated in Miranda, regardless of the nature or severity of the offense of which he is suspected or for which he was arrested.
The Court found in New York v. Quarles, 467 U.S. 649 (1984), that there is also a "public safety" exception to the requirement that Miranda warnings be given before questioning: for example, if the defendant is in possession of information regarding the location of an unattended gun or there are other similar exigent circumstances which require protection of the public, the defendant may be questioned without warning and his responses, though incriminating, will be admissible in evidence. In 2009, the California Supreme Court upheld the conviction of Richard Allen Davis, finding that the public safety exception applied despite the fact that 64 days had passed from the disappearance of the girl later found to be murdered.[21]
The Court found in Colorado v. Connelly, 479 U.S. 157 (1986), that the words "knowing, intelligent, and voluntary" mean only that suspects reasonably appear to understand what they are doing and are not being coerced into signing the waiver; the Court ruled that it is irrelevant whether the suspect may actually have been insane at the time.
United States v. Garibay (1998) pointed out an important matter in regards to expansion of Miranda. Garibay barely spoke English and clearly showed a lack of understanding; indeed, "the agent admitted that he had to rephrase questions when the defendant appeared confused."[22] The U.S. Court of Appeals ruled a "clear error" when the district court found that Garibay had "knowingly and intelligently waived his Miranda rights" due to the defendant’s low I.Q. and poor English language skills.[23] The court investigated many facets of his waiver and discovered that Mr. Garibay was missing all items that they were looking for: he never signed a waiver, he only received his warnings verbally and in English, and no interpreter was provided although they were available. With an opinion that stressed "the requirement that a defendant 'knowingly and intelligently' waive his Miranda rights", the Court reversed Garibay's conviction and remanded his case.[23]
Miranda survived a strong challenge in Dickerson v. United States, 530 U.S. 428 (2000), where the validity of Congress's overruling of Miranda through § 3501 was tested. At issue was whether the Miranda warnings were actually compelled by the Constitution, or were rather merely measures enacted as a matter of judicial policy.[citation needed] In Dickerson, the Court, speaking through Chief Justice Rehnquist, upheld Miranda 7–2 and stated that "the warnings have become part of our national culture". In dissent, Justice Scalia argued Miranda warnings were not constitutionally required. He cited several cases demonstrating a majority of the then-current court, counting himself, and Justices Kennedy, O'Connor, and Thomas, as well as the Chief Justice (who had just delivered a contrary opinion), "[were] on record as believing that a violation of Miranda is not a violation of the Constitution".[citation needed]
Over time, interrogators began to think of techniques to honor the "letter" but not the "spirit" of Miranda. In the case of Missouri v. Seibert, 542 U.S. 600 (2004), the Supreme Court halted one of the more controversial practices. Missouri police were deliberately withholding Miranda warnings and questioning suspects until they obtained confessions, then giving the warnings, getting waivers, and getting confessions again. Justice Souter wrote for the plurality: "Strategists dedicated to draining the substance out of Miranda cannot accomplish by training instructions what Dickerson held Congress could not do by statute."[24]
Berghuis v. Thompkins (2010) is a ruling where the Supreme Court held that a suspect's "ambiguous or equivocal" statement or no statements do not mean that police must end an interrogation.[25] At least one scholar has argued that Thompkins effectively gutted Miranda. In The Right to Remain Silent, Charles Weisselberg wrote that "the majority in Thompkins rejected the fundamental underpinnings of Miranda v. Arizona’s prophylactic rule and established a new one that fails to protect the rights of suspects" and that
But in Thompkins, neither Michigan nor the Solicitor General were able to cite any decision in which a court found that a suspect had given an implied waiver after lengthy questioning. Thompkins persevered for almost three hours before succumbing to his interrogators. In finding a waiver on these facts, Thompkins gives us an implied waiver doctrine on steroids.[1]
See also[edit]
United States constitutional criminal procedure
Berghuis v. Thompkins
Berkemer v. McCarty
Escobedo v. Illinois
Stansbury v. California
List of criminal competencies
List of United States Supreme Court cases, volume 384
Miranda warning
Schmerber v. California
R. v. Hebert
R. v. Brydges
References[edit]
^ Jump up to: a b Charles Weisselberg and Stephanos Bibas, The Right to Remain Silent, 159 U. Pa. L. Rev. PENNumbra 69 (2010), Available at: http://scholarship.law.berkeley.edu/facpubs/2181 (Retrieved May 2, 2016)
Jump up ^ Miranda also matched the description given by a robbery victim of the perpetrator in a robbery several months earlier. He was simultaneously interrogated about both of these crimes, confessed to both, but was not asked to and did not write down his confession to the robbery. He was separately tried and convicted of the robbery and sentenced to 20 to 25 years of imprisonment. This crime, trial, and sentence is separate from the rape-kidnapping case appealed to the Supreme Court.
Jump up ^ Michael S. Lief and H. Mitchell Caldwell "'You Have the Right to Remain Silent,'" American Heritage, August/September 2006.
Jump up ^ Miranda's oral confession in the robbery case was also appealed and the Arizona Supreme Court likewise affirmed the trial decision to admit it in State v. Miranda, 401 P.2d 716. This case was not part of the appeal to the Supreme Court of the United States.
Jump up ^ Oliver, Myrna (September 12, 2002). "John P. Frank, 84; Attorney Won Key Decision in 1966 Miranda Case". Los Angeles Times. Retrieved May 12, 2017.
Jump up ^ Supreme Court of the United States. 2/2/1790- (1966-06-13). Opinion of the Court by Chief Justice Earl Warren in the Case of Miranda v. Arizona. File Unit: Appellate Jurisdiction Case File Miranda v. Arizona, 1965 - 1966.
Jump up ^ Syllabus to the U.S. Supreme Court decision in Miranda v. Arizona, holding 1.(d).
Jump up ^ State v. Miranda, 104 Ariz. 174, 176, 450 P.2d 364, 366 (1969).
^ Jump up to: a b c Lief, Michael S.; H. Mitchell Caldwell (Aug–Sep 2006). "You Have The Right To Remain Silent". American Heritage. Archived from the original on 2009-02-06. Retrieved 2011-08-24.
Jump up ^ State v. Miranda, 104 Ariz. 174, 450 P.2d 364 (1969)
Jump up ^ 396 U.S. 868 (1969).
Jump up ^ "Miranda Slain; Main Figure in Landmark Suspects' Rights Case". The New York Times. February 1, 1976. Retrieved May 12, 2010.
Jump up ^ Charles Montaldo, Miranda Rights and Warning: Landmark Case Evolved from 1963 Ernesto Miranda Arrest, about.com; accessed 13 June 2014.
Jump up ^ "The Law: Catching Up with Miranda". Time. March 3, 1967. Retrieved November 7, 2011.
Jump up ^ "What Are Your Miranda Rights". ExpertLaw. 2017-05-01. Retrieved 2017-05-01.
Jump up ^ See, e.g., "Colorado v. Spring, 479 U.S. 564, 856-57 (1987)". Google Scholar. Google. Retrieved 18 March 2018.
Jump up ^ Edwards, H. Lynn (1966). "The Effects of Miranda on the Work of the Federal Bureau of Investigation". American Criminal Law Quarterly. 159: 160–161. Retrieved 18 March 2018.
Jump up ^ "Miranda Waiver" (PDF). University Police Department. University of North Alabama. Retrieved 18 March 2018.
Jump up ^ "Handcuffing the Cops: Miranda's Harmful Effects on Law Enforcement | NCPA". 2015-05-18. Archived from the original on 2015-05-18. Retrieved 2016-09-28. CS1 maint: BOT: original-url status unknown (link)
Jump up ^ "Cite Miranda And Go Free". Sarasota Journal. 31 May 1968. p. 7.
Jump up ^ People vs. Davis, S056425.
Jump up ^ Einesman, Floralynn (1999). "Confessions and Culture: The Interaction of Miranda and Diversity". Journal of Criminal Law and Criminology. 90 (1): 1–48 [p. 41]. JSTOR 1144162. NCJ 182327.
^ Jump up to: a b United States Court of Appeals, Ninth Circuit (May 5, 1998), UNITED STATES of America, Plaintiff-Appellee, v. Jose Rosario GARIBAY, Jr., Defendant-Appellant. No. 96-50606., retrieved February 15, 2017
Jump up ^ "Missouri v. Seibert, section VI". Archived from the original on May 25, 2009. Retrieved 2010-05-07. Hosted by Duke University School of Law.
Jump up ^ Berghuis v. Thompkins, 560 U.S. 370 (2010).
Further reading[edit]
Baker, Liva (1983). Miranda: Crime, law, and politics. New York: Atheneum. ISBN 0-689-11240-8.
Kassin, Saul M.; Norwick, Rebecca J. (2004). "Why People Waive Their Miranda Rights: The Power of Innocence". Law and Human Behavior. 28 (2): 211–221. doi:10.1023/B:LAHU.0000022323.74584.f5.
Levy, Leonard W. (1986) [1969]. Origins of the Fifth Amendment (Reprint ed.). New York: Macmillan. ISBN 0-02-919580-2.
Soltero, Carlos R. (2006). "Miranda v. Arizona (1966) and the rights of the criminally accused". Latinos and American Law: Landmark Supreme Court Cases. Austin, TX: University of Texas Press. pp. 61–74. ISBN 0-292-71411-4.
Stuart, Gary L. (2004). Miranda: The Story of America's Right to Remain Silent. Tucson, Arizona: University of Arizona Press. ISBN 0-8165-2313-4.
External links[edit]
Wikisource has original text related to this article:
Miranda v. Arizona
Text of Miranda v. Arizona, (1966)384 U.S. 436 (1966) is available from: Cornell CourtListener Findlaw Justia Oyez OpenJurist Google Scholar
"Supreme Court Landmark Case Miranda v. Arizona" from C-SPAN's Landmark Cases: Historic Supreme Court Decisions
An online publication titled "Miranda v. Arizona: The Rights to Justice" containing the most salient documents and other primary and secondary sources from the Law Library of Congress
Retrieved from "https://en.wikipedia.org/w/index.php?title=Miranda_v._Arizona&oldid=835403766"
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Photosynthetic efficiency
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The photosynthetic efficiency is the fraction of light energy converted into chemical energy during photosynthesis in plants and algae. Photosynthesis can be described by the simplified chemical reaction
6H2O + 6CO2 + energy → C6H12O6 + 6O2
where C6H12O6 is glucose (which is subsequently transformed into other sugars, cellulose, lignin, and so forth). The value of the photosynthetic efficiency is dependent on how light energy is defined – it depends on whether we count only the light that is absorbed, and on what kind of light is used (see Photosynthetically active radiation). It takes eight (or perhaps 10 or more[1]) photons to utilize one molecule of CO2. The Gibbs free energy for converting a mole of CO2 to glucose is 114 kcal, whereas eight moles of photons of wavelength 600 nm contains 381 kcal, giving a nominal efficiency of 30%.[2] However, photosynthesis can occur with light up to wavelength 720 nm so long as there is also light at wavelengths below 680 nm to keep Photosystem II operating (see Chlorophyll). Using longer wavelengths means less light energy is needed for the same number of photons and therefore for the same amount of photosynthesis. For actual sunlight, where only 45% of the light is in the photosynthetically active wavelength range, the theoretical maximum efficiency of solar energy conversion is approximately 11%. In actuality, however, plants do not absorb all incoming sunlight (due to reflection, respiration requirements of photosynthesis and the need for optimal solar radiation levels) and do not convert all harvested energy into biomass, which results in an overall photosynthetic efficiency of 3 to 6% of total solar radiation.[1] If photosynthesis is inefficient, excess light energy must be dissipated to avoid damaging the photosynthetic apparatus. Energy can be dissipated as heat (non-photochemical quenching), or emitted as chlorophyll fluorescence.
Contents
[hide]
1 Typical efficiencies
1.1 Plants
1.2 Algae and other monocellular organisms
1.2.1 Worldwide figures
2 Efficiencies of various biofuel crops
3 C3 vs. C4 and CAM plants
4 See also
5 References
Typical efficiencies[edit]
Plants[edit]
Quoted values sunlight-to-biomass efficiency
Plant
Efficiency
Plants, typical 0.1%[3]
0.2–2%[4]
Typical crop plants 1–2%[3]
The following is a breakdown of the energetics of the photosynthesis process from Photosynthesis by Hall and Rao:[5]
Starting with the solar spectrum falling on a leaf,
47% lost due to photons outside the 400–700 nm active range (chlorophyll utilizes photons between 400 and 700 nm, extracting the energy of one 700 nm photon from each one)
30% of the in-band photons are lost due to incomplete absorption or photons hitting components other than chloroplasts
24% of the absorbed photon energy is lost due to degrading short wavelength photons to the 700 nm energy level
68% of the utilized energy is lost in conversion into d-glucose
35–45% of the glucose is consumed by the leaf in the processes of dark and photo respiration
Stated another way:
100% sunlight → non-bioavailable photons waste is 47%, leaving
53% (in the 400–700 nm range) → 30% of photons are lost due to incomplete absorption, leaving
37% (absorbed photon energy) → 24% is lost due to wavelength-mismatch degradation to 700 nm energy, leaving
28.2% (sunlight energy collected by chlorophyl) → 32% efficient conversion of ATP and NADPH to d-glucose, leaving
9% (collected as sugar) → 35–40% of sugar is recycled/consumed by the leaf in dark and photo-respiration, leaving
5.4% net leaf efficiency.
Many plants lose much of the remaining energy on growing roots. Most crop plants store ~0.25% to 0.5% of the sunlight in the product (corn kernels, potato starch, etc.).
Photosynthesis increases linearly with light intensity at low intensity, but at higher intensity this is no longer the case (see Photosynthesis-irradiance curve). Above about 10,000 lux or ~100 watts/square meter the rate no longer increases. Thus, most plants can only utilize ~10% of full mid-day sunlight intensity.[5] This dramatically reduces average achieved photosynthetic efficiency in fields compared to peak laboratory results. However, real plants (as opposed to laboratory test samples) have lots of redundant, randomly oriented leaves. This helps to keep the average illumination of each leaf well below the mid-day peak enabling the plant to achieve a result closer to the expected laboratory test results using limited illumination.
Only if the light intensity is above a plant specific value, called the compensation point the plant assimilates more carbon and releases more oxygen by photosynthesis than it consumes by cellular respiration for its own current energy demand.
Photosynthesis measurement systems are not designed to directly measure the amount of light absorbed by the leaf. Nevertheless, the light response curves that the class produces do allow comparisons in photosynthetic efficiency between plants.
Algae and other monocellular organisms[edit]
From a 2010 study by the University of Maryland, photosynthesizing Cyanobacteria have been shown to be a significant species in the global carbon cycle, accounting for 20–30% of Earth's photosynthetic productivity and convert solar energy into biomass-stored chemical energy at the rate of ~450 TW.[6]
Worldwide figures[edit]
According to the cyanobacteria study above, this means the total photosynthetic productivity of earth is between ~1500–2250 TW, or 4.73–7.10 x 1022 J (47,300–71,000 exajoules) per year. Using this source's figure of 178,000 TW of solar energy hitting the Earth's surface,[6] the total photosynthetic efficiency of the planet is 0.84% to 1.26% (see also Earth's energy budget).
Efficiencies of various biofuel crops[edit]
Popular choices for plant biofuels include: oil palm, soybean, castor oil, sunflower oil, safflower oil, corn ethanol, and sugar cane ethanol.
An analysis[original research?] of a proposed Hawaiian oil palm plantation claimed to yield 600 gallons of biodiesel per acre per year. That comes to 2835 watts per acre or 0.7 W/m2.[7][irrelevant citation] Typical insolation in Hawaii is around 5.5 kWh/(m2day) or 230 W/m2.[8] For this particular oil palm plantation, if it delivered the claimed 600 gallons of biodiesel per acre per year, would be converting 0.3% of the incident solar energy to chemical fuel. Total photosynthetic efficiency would include more than just the biodiesel oil, so this 0.3% number is something of a lower bound.
Contrast this with a typical photovoltaic installation,[9] which would produce an average of roughly 22 W/m2 (roughly 10% of the average insolation), throughout the year. Furthermore, the photovoltaic panels would produce electricity, which is a high-quality form of energy, whereas converting the biodiesel into mechanical energy entails the loss of a large portion of the energy. On the other hand, a liquid fuel is much more convenient for a vehicle than electricity, which has to be stored in heavy, expensive batteries.
Most crop plants store ~0.25% to 0.5% of the sunlight in the product (corn kernels, potato starch, etc.), sugar cane is exceptional in several ways to yield peak storage efficiencies of ~8%.[citation needed]
Ethanol fuel in Brazil has a calculation that results in: "Per hectare per year, the biomass produced corresponds to 0.27 TJ. This is equivalent to 0.86 W/m2. Assuming an average insolation of 225 W/m2, the photosynthetic efficiency of sugar cane is 0.38%." Sucrose accounts for little more than 30% of the chemical energy stored in the mature plant; 35% is in the leaves and stem tips, which are left in the fields during harvest, and 35% are in the fibrous material (bagasse) left over from pressing.[citation needed]
C3 vs. C4 and CAM plants[edit]
C3 plants use the Calvin cycle to fix carbon. C4 plants use a modified Calvin cycle in which they separate Ribulose-1,5-bisphosphate carboxylase oxygenase (RuBisCO) from atmospheric oxygen, fixing carbon in their mesophyll cells and using oxaloacetate and malate to ferry the fixed carbon to RuBisCO and the rest of the Calvin cycle enzymes isolated in the bundle-sheath cells. The intermediate compounds both contain four carbon atoms, which gives C4. In Crassulacean acid metabolism (CAM), time isolates functioning RuBisCo (and the other Calvin cycle enzymes) from high oxygen concentrations produced by photosynthesis, in that O2 is evolved during the day, and allowed to dissipate then, while at night atmospheric CO2 is taken up and stored as malic or other acids. During the day, CAM plants close stomata and use stored acids as carbon sources for sugar, etc. production.
The C3 pathway requires 18 ATP for the synthesis of one molecule of glucose while the C4 pathway requires 20 ATP. Despite this reduced ATP efficiency, C4 is an evolutionary advancement, adapted to areas of high levels of light, where the reduced ATP efficiency is more than offset by the use of increased light. The ability to thrive despite restricted water availability maximizes the ability to use available light. The simpler C3 cycle which operates in most plants is adapted to wetter darker environments, such as many northern latitudes.[citation needed]. Corn, sugar cane, and sorghum are C4 plants. These plants are economically important in part because of their relatively high photosynthetic efficiencies compared to many other crops[citation needed]. Pineapple is a CAM plant.
See also[edit]
Energy conversion efficiency
FLEX (satellite)
Phototroph
Photosynthetically active radiation
References[edit]
^ Jump up to: a b Renewable biological systems for unsustainable energy production. FAO Agricultural Services Bulletins (1997).
Jump up ^ Lubert Stryer (1981). Biochemistry (2nd ed.). p. 448. ISBN 0-7167-1226-1.
^ Jump up to: a b Govindjee, What is photosynthesis?
Jump up ^ The Green Solar Collector; converting sunlight into algal biomass Wageningen University project (2005—2008)
^ Jump up to: a b David Oakley Hall; K. K. Rao; Institute of Biology (1999). Photosynthesis. Cambridge University Press. ISBN 978-0-521-64497-6. Retrieved 3 November 2011.
^ Jump up to: a b Pisciotta JM, Zou Y, Baskakov IV (2010). "Light-Dependent Electrogenic Activity of Cyanobacteria". PLoS ONE. 5 (5): e10821. doi:10.1371/journal.pone.0010821. PMC 2876029  . PMID 20520829.
Jump up ^ Biodiesel Fuel. Ag.ndsu.edu.. Retrieved on 2011-11-03.
Jump up ^ PVWATTS: Hawaii. Rredc.nrel.gov. Retrieved on 2011-11-03.
Jump up ^ NREL: In My Backyard (IMBY) Home Page. Nrel.gov (2010-12-23). Retrieved on 2011-11-03.
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