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Michigan v. Jackson

Supreme Court of the United States · 1986 · Criminal Procedure

Criminal ProcedureSixth AmendmentRight to CounselCustodial InterrogationWaiverSixth Amendmentarraignmentrequest for counsel

Facts

In both consolidated cases, the defendants were arraigned, formally charged, and requested appointed counsel because they were indigent. Before either defendant had an opportunity to consult with counsel, police initiated further custodial interrogation, gave Miranda warnings, obtained agreement to speak without counsel present, and secured incriminating statements. In both cases, officers involved in the investigations were present at the arraignments. The challenged statements were the postarraignment confessions obtained after the defendants had requested counsel at arraignment.

Issue

Whether, after a defendant has been formally charged and has requested appointment of counsel at arraignment, police may initiate further custodial interrogation and obtain a valid waiver of the defendant's right to counsel based on renewed Miranda warnings and the defendant's agreement to talk. Put differently, does the Edwards rule apply in this Sixth Amendment setting?

Rule

If police initiate interrogation after a defendant's assertion, at an arraignment or similar proceeding, of the right to counsel, any waiver of the defendant's right to counsel for that police-initiated interrogation is invalid, 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 Cleveland, Omar Ruiz was arraigned on burglary charges and told the judge he wanted appointed counsel because he could not afford a lawyer. The next afternoon, before any lawyer had met with him, detectives came to the jail, gave Miranda warnings, and asked to hear his side of the story; Omar agreed and made incriminating statements.

Are Omar's statements admissible?

Explanation. The majority held that once a formally charged defendant asserts the right to counsel at arraignment or a similar proceeding, police may not initiate further interrogation until counsel has been made available, unless the accused initiates the contact. Renewed Miranda warnings and acquiescence do not validate a police-initiated waiver in that setting.