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Edwards v. Arizona

Supreme Court of the United States · 1981 · Criminal Procedure

Criminal ProcedureCustodial InterrogationMiranda Right to CounselWaiverMirandaright to counselcustodial interrogationwaiver

Facts

After Edwards was arrested and advised of his Miranda rights, he agreed to talk, denied involvement, and gave an alibi statement. He then said, "I want an attorney before making a deal," and questioning stopped. The next morning, without counsel being provided, detectives came to the jail to speak with him; although Edwards told the detention officer he did not want to talk to anyone, he was taken to the detectives, advised again of his Miranda rights, and ultimately made an incriminating oral statement. That statement was admitted at trial over his objection.

Issue

When a suspect in custody has invoked the right to have counsel present during interrogation, may police later reinitiate custodial interrogation without first making counsel available and rely on the suspect's responses after renewed Miranda warnings as a valid waiver? More specifically, did Edwards validly waive his previously invoked right to counsel when police returned the next day and questioned him?

Rule

A waiver of the right to counsel must be not only voluntary but also a knowing and intelligent relinquishment of a known right. When an accused has invoked the right to have counsel present during custodial interrogation, a valid waiver cannot be established merely by showing that he responded to further police-initiated custodial interrogation after being advised of his rights. Once the accused has expressed a desire to deal with police only through counsel, he is not subject to further interrogation until counsel has been made available, unless the accused himself initiates further communication, exchanges, or conversations with the police.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, detectives arrested Nolan Pierce for arson and read him Miranda warnings. Nolan said he understood and answered a few questions, but then stated, "I want a lawyer here before any more questions," so the interview ended. The next afternoon, without providing counsel, detectives returned to the jail, read Miranda warnings again, and Nolan agreed to talk and confessed.

Is Nolan's confession admissible in the prosecution's case-in-chief?

Explanation. The majority held that after a suspect in custody invokes the right to have counsel present during interrogation, authorities may not subject him to further police-initiated custodial interrogation until counsel has been made available, unless the accused himself initiates further communication. A valid waiver cannot be shown merely by proving that police gave fresh Miranda warnings and the suspect then answered questions. Nolan's statement is therefore inadmissible.