Law School Case Brief
Massiah v. United States - 377 U.S. 201, 84 S. Ct. 1199 (1964)
A defendant is denied the basic protections of the Sixth Amendment when there is used against him at his trial evidence of his own incriminating words, which federal agents have deliberately elicited from him after he has been indicted and in the absence of his counsel. If such a rule is to have any efficacy, it must apply to indirect and surreptitious interrogations as well as to those conducted in the jailhouse.
Defendant Massiah, after being indicted with other persons for violating the federal narcotics laws, retained a lawyer, pleaded not guilty, and was released on bail. While free on bail, defendant held a conversation in the absence of his counsel with one of his co-defendants while sitting in the latter's automobile. Defendant was unaware that the co-defendant was cooperating with government agents, and allowed the installation of a radio transmitter under the front seat of the automobile, by means of which a federal agent listened to the conversation. At defendant's trial in the United States District Court for the Southern District of New York, the federal agent testified to incriminating statements made by defendant during the conversation over defendant's objection. The trial resulted in defendant's conviction. On defendant's appeal, the United States Court of Appeals for the Second Circuit affirmed the conviction.
Was defendant's conviction proper?
The Supreme Court of the United States reversed. In an opinion by Stewart, J., the Court held that under the Sixth Amendment's guaranty of defendant's right to assistance of counsel, defendant's incriminating statements, elicited by government agents after he had been indicted and in the absence of his counsel, were not admissible at his trial. The Court further held that defendant was denied the basic protections of U.S. Const. amend. VI when there was used against him at his trial evidence of his own incriminating words, which federal agents had deliberately and secretly elicited from him after he had been indicted and in the absence of his counsel. The Court found that any secret interrogation of defendant, from and after the finding of the indictment, without the protection afforded by the presence of counsel, contravened the basic dictates of fairness in the conduct of the criminal cause and the fundamental rights of the accused. The Court noted that defendant was as much entitled to aid of counsel during the critical period after arraignment and until the beginning of trial as at the trial itself. Here, defendant was seriously imposed upon since he did not even know that he was under interrogation by a government agent.
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