Law School Case Brief
Connecticut v. Barrett - 479 U.S. 523, 107 S. Ct. 828 (1987)
The United States Supreme Court does not denigrate the settled approach to questions of waiver that requires it to give a broad, rather than a narrow, interpretation to a defendant's request for counsel, when it observes that this approach does little to aid a defendant's cause. Interpretation is only required where the defendant's words, understood as ordinary people would understand them, are ambiguous
Respondent William Barrett, while in custody on suspicion of sexual assault, was advised three times of his Miranda rights by the police. On each occasion, after signing and dating an acknowledgment that he had been given those rights, Barrett indicated to the police that he would not make a written statement, but that he was willing to talk about the incident that led to his arrest. On the second and third such occasions, Barrett added that he would not make a written statement outside the presence of counsel, but then orally admitted his involvement in the sexual assault. One of the police officers reduced to writing his recollection of Barrett's last such statement, and the confession was introduced into evidence at Barrett's trial. The trial court refused to suppress the confession, finding that Barrett had fully understood the Miranda warnings and had voluntarily waived his right to counsel. Barrett’s conviction of sexual assault, inter alia, was reversed by the Connecticut Supreme Court, which held that his expressed desire for counsel before making a written statement constituted an invocation of his right to counsel for all purposes, that he had not waived that right by initiating further discussion with the police, and that therefore the incriminating statement was improperly admitted into evidence under Edwards v. Arizona, 451 U.S. 477. The State filed a petition for certiorari review.
Did the Connecticut Supreme Court err in suppressing Barrett’s incriminating statements?
The United States Supreme Court held that it was error to hold that the United States Constitution required suppression of Barrett's oral statement. The Court found that Barrett's limited requests for counsel were accompanied by affirmative announcements of his willingness to speak with the authorities. The fact that the authorities took the opportunity provided by Barrett to obtain an oral confession was consistent with the Fifth Amendment. The Court stated that to conclude that Barrett had invoked his right to counsel for all purposes, both his oral and written statements, required not a broad interpretation of an ambiguous statement, but a disregard of the ordinary meaning of his statement.
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