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Law School Case Brief

Edwards v. Arizona - 451 U.S. 477, 101 S. Ct. 1880 (1981)

Rule:

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.

Facts:

After being arrested on a state criminal charge, and after being informed of his rights as required by Miranda v. Arizona, petitioner Edwards was questioned by the police on Jan. 19, 1976, until he said that he wanted an attorney. Questioning then ceased, but on Jan. 20 police officers came to the jail and, after stating that they wanted to talk to him and again informing him of his Miranda rights, obtained his confession when he said that he was willing to talk. At trial in Arizona state court, the trial court ultimately denied Edwards' motion to suppress his confession, finding the statement to be voluntary. Edwards was convicted, and he appealed. The Supreme Court of Arizona held that during the Jan. 20 meeting Edwards waived his right to remain silent and his right to counsel when he voluntarily gave his statement after again being informed of his rights. Edwards filed a petition for certiorari, which was granted.

Issue:

Did the Fifth, Sixth, and Fourteenth Amendments require suppression of a post-arrest confession, which was obtained after Edwards had invoked his right to consult counsel before further interrogation?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States held that the use of Edwards' confession against him violated his Fifth and Fourteenth Amendment rights in that he 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. The Court averred that Edwards 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. Moreover, the Court opined that having requested counsel, Edwards was not subject to further interrogation until counsel had been made available to him, unless Edwards himself initiated further communication with the police. Hence, the Court reversed the state supreme court's judgment.

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