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Edwards v. Ariz.

Supreme Court of the United States

November 5, 1980, Argued ; May 18, 1981, Decided

No. 79-5269

Case Summary

Procedural Posture

Petitioner was convicted of robbery, burglary, and first degree murder. The trial court admitted his post-arrest confession, and the Supreme Court of Arizona affirmed the admission, holding that the confession was valid despite the fact that petitioner had invoked his Fifth Amendment right to counsel during a previous interrogation. The Supreme Court granted petitioner's request for a writ of certiorari.

Overview

After he was arrested and read his Miranda rights, petitioner requested an attorney. The police officers ceased questioning, but detectives from the same police department returned the next day and again interrogated petitioner. Petitioner confessed to the crimes during the second interrogation. The lower courts held that although petitioner had invoked his right to remain silent and his right to counsel, he had waived both rights during the second interrogation after again being informed of his Miranda rights. The Supreme Court held that (1) the use of petitioner's confession against him violated his Fifth and Fourteenth Amendment rights, where petitioner had asserted his right to counsel and his right to remain silent, and the police, without furnishing him with counsel, returned and secured a confession; (2) petitioner did not validly waive his right to counsel, where there was no finding that he understood his right to counsel and intelligently and knowingly relinquished it; and (3) having requested counsel, petitioner was not subject to further interrogation until counsel had been made available to him, unless petitioner himself initiated further communication with the police.

Outcome

The Supreme Court reversed the appellate court's holding that defendant had validly waived his right to counsel.

LexisNexis® Headnotes

 

 

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Self-Incrimination Privilege

Criminal Law & Procedure > Commencement of Criminal Proceedings > Interrogation > General Overview

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > General Overview

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Custodial Interrogation

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > Notice & Warning

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Right to Counsel During Questioning

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > Self-Incrimination Privilege

Criminal Law & Procedure > Counsel > Right to Counsel > General Overview

HN1  Procedural Due Process, Self-Incrimination Privilege

The Fifth and Fourteenth Amendments' prohibition against compelled self-incrimination requires that custodial interrogation be preceded by advice to the putative defendant that he has the right to remain silent and also the right to the presence of an attorney. If the accused indicates that he wishes to remain silent, the interrogation must cease. If he requests counsel, the interrogation must cease until an attorney is present. Thus, an accused has a Fifth and Fourteenth Amendment right to have counsel present during custodial interrogation.

 

Constitutional Law > ... > Fundamental Rights > Criminal Process > Assistance of Counsel

Criminal Law & Procedure > Counsel > Right to Counsel > General Overview

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Right to Counsel During Questioning

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > Voluntary Waiver

HN2  Criminal Process, Assistance of Counsel

Waivers of counsel must not only be voluntary, but must also constitute a knowing and intelligent relinquishment or abandonment of a known right or privilege, a matter which depends in each case upon the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused.

 

Constitutional Law > ... > Fundamental Rights > Criminal Process > Assistance of Counsel

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Custodial Interrogation

Criminal Law & Procedure > Commencement of Criminal Proceedings > Interrogation > General Overview

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > General Overview

Criminal Law & Procedure > ... > Miranda Rights > Self-Incrimination Privilege > Right to Counsel During Questioning

Criminal Law & Procedure > ... > Interrogation > Miranda Rights > Voluntary Waiver

Criminal Law & Procedure > Counsel > Right to Counsel > General Overview

HN3  Criminal Process, Assistance of Counsel

When an accused has invoked his right to have counsel present during a custodial interrogation, a valid waiver of that right cannot be established by showing only that he responded to further police-initiated custodial interrogation even if he has been advised of his rights. An accused, having expressed his desire to deal with the police only through counsel, is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication, exchanges, or conversations with the police.

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451 U.S. 477 ; 101 S. Ct. 1880 ; 68 L. Ed. 2d 378 ; 1981 U.S. LEXIS 96 ; 49 U.S.L.W. 4496

EDWARDS v. ARIZONA

Prior History:  [1]  CERTIORARI TO THE SUPREME COURT OF ARIZONA.

Disposition:  122 Ariz. 206, 594 P. 2d 72, reversed.