Law School Case Brief
Arizona v. Roberson - 486 U.S. 675, 108 S. Ct. 2093 (1988)
The prophylactic protections that the Miranda warnings provide to counteract the "inherently compelling pressures" of custodial interrogation and to permit a full opportunity to exercise the privilege against self-incrimination are implemented by the application of the Edwards corollary that if a suspect believes that he is not capable of undergoing such questioning without advice of counsel, then it is presumed that any subsequent waiver that has come at the authorities' behest, and not at the suspect's own instigation, is itself the product of the "inherently compelling pressures" and not the purely voluntary choice of the suspect. Where the accused has expressed his own view that he is not competent to deal with the authorities without legal advice, a later decision at the authorities' insistence to make a statement without counsel's presence may properly be viewed with skepticism.
Defendant Roberson was arrested for burglary and was given the warnings required by Miranda v Arizona (1966) 384 US 436, 16 L Ed 2d 694, 88 S Ct 1602. Defendant replied that he wanted a lawyer before answering any questions, and this fact was duly recorded in the arresting officer's report. Three days later, while defendant was still in police custody, a second officer interrogated him about a previous burglary. The second officer, who was not aware that defendant had earlier requested counsel, advised defendant of his rights and obtained an incriminating statement concerning the previous burglary. In the prosecution for that offense in an Arizona trial court, that statement was suppressed. The trial court based its ruling on a decision from the Supreme Court of Arizona that applied the rule established in Edwards v Arizona (1981) 451 US 477, 68 L Ed 2d 378, 101 S Ct 1880, that a criminal suspect undergoing custodial interrogation who has expressed a desire to deal with the police only through counsel was not subject to further interrogation by the authorities until counsel was made available to the suspect, unless the suspect initiated further communication, exchanges, or conversations with the police. The Court of Appeals of Arizona, Division Two, affirmed the suppression order, and the Supreme Court of Arizona denied a petition for review.
Was it proper to suppress the incriminating statement obtained from defendant during the second interrogation?
The Supreme Court of the United States held that the bright-line, prophylactic Edwards rule applied because the police-initiated interrogation followed defendant’s request for counsel even though the interrogation occurred in the context of a separate investigation. The Court attached no significance to the fact that the officer who conducted the second interrogation did not know that defendant had made a request for counsel. The Court ruled that whether the re-interrogation concerned the same or a different offense, or whether the same or different law enforcement authorities were involved in the second investigation, the same need to determine whether the suspect had requested counsel existed. The Court posited that the police department's failure to honor that request could not be justified by the lack of diligence of a particular officer.
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