Law School Case Brief
Duckworth v. Eagan - 492 U.S. 195, 109 S. Ct. 2875 (1989)
There are certain procedural safeguards that require police to advise criminal suspects of their rights under the Fifth and Fourteenth Amendments before commencing custodial interrogation. The suspect must be told that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires. Interrogation in certain custodial circumstances is presumed to be inherently coercive and statements made under those circumstances are inadmissible unless the suspect is specifically warned of his Miranda rights and freely decides to forgo those rights.
Respondent, when first questioned by Indiana police in connection with a stabbing, made an exculpatory statement after being read and signing a waiver form that provided, inter alia, that if he could not afford a lawyer, one would be appointed for him "if and when you go to court." However, 29 hours later, he was interviewed again, signed a different waiver form, confessed to the stabbing, and led officers to a site where they recovered relevant physical evidence. Over respondent's objection, his two statements were admitted into evidence at trial. After the Indiana Supreme Court upheld his conviction for attempted murder, respondent sought a writ of habeas corpus in the federal district court claiming, among other things, that his confession was inadmissible because the first waiver form did not comply with the requirements of Miranda v. Arizona, 384 U.S. 436. The district court denied the petition, holding that the record clearly manifested adherence to Miranda. The Court of Appeals for the Seventh Circuit reversed on the ground that the advice that counsel will be appointed "if and when you go to court" was constitutionally defective because it denied the indigent accused a clear and unequivocal warning of the right to appointed counsel before interrogation and linked that right to a future event. The United States Supreme Court granted certiorari review.
Did the police officer’s advice to the respondent adhere to the requirements of Miranda?
The Court held that the initial warnings given to the respondent touched all of the bases required by Miranda. According to the Court, the "if and when you go to court" advice simply anticipated that question. Miranda did not require that attorneys be producible on call, but only that the suspect be informed, as here, that he had the right to an attorney before and during questioning, and that an attorney would be appointed for him if he could not afford one.
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