Law School Case Brief
Patterson v. Illinois - 487 U.S. 285, 108 S. Ct. 2389 (1988)
So long as an accused is made aware of the dangers and disadvantages of self-representation during postindictment questioning, by use of the Miranda warnings, his waiver of his Sixth Amendment right to counsel at such questioning is "knowing and intelligent."
Defendant Tyrone Patterson, a gang member, was accused of participating in a murder. After he was indicted, and while he was in custody, Patterson started to make a statement about the murder to a police officer. The officer interrupted him and handed him a waiver form containing five specific Miranda warnings. Patterson read and signed the form and then gave a statement describing his role in the murder. Later that day, Patterson gave a second inculpatory statement to a state attorney, after reviewing and reaffirming his previous waiver and repeating the waiver process. Before trial in Illinois state court, Patterson filed a motion to suppress his statements. The trial court denied the motion and permitted the statements to be used against Patterson, who was found guilty. On appeal, Patterson argued that he had not knowingly and intelligently waived his right to counsel under the Sixth Amendment and that the Sixth Amendment requires a higher standard for showing waiver of the right to counsel than that required for Miranda waivers. The appellate court affirmed, holding that Patterson understood his Sixth Amendment rights before he gave his statements. The Supreme Court of Illinois affirmed on similar grounds. Patterson was granted a writ of certiorari.
Did the interrogation of Patterson after his indictment violate his Sixth Amendment right to counsel?
The Supreme Court of the United States affirmed the state supreme court's judgment. The Court held that an accused, such as Patterson, who was admonished with Miranda warnings was sufficiently apprised of the nature of his U.S. Const. amend. VI rights and of the consequences of abandoning those rights, so that his waiver on that basis would be considered a knowing and intelligent one. The Court stated that it seemed self-evident that one who was told that he had such rights to counsel was in a curious posture to later complain that his waiver of those rights was unknowing. The court further ruled that the police were not barred from initiating a post-indictment interrogation meeting with an accused who had not sought to exercise the Sixth Amendment right to counsel.
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