Massiah v. United States

Background

A merchant seaman was indicted on federal narcotics charges, retained a lawyer, pleaded not guilty, and was released on bail. A co-defendant, without the seaman’s knowledge, let a federal agent install a radio transmitter in his car. The agent overheard a long conversation in which the seaman made incriminating statements, and the agent then testified about those statements at trial over defense objections. The jury convicted the seaman and the Court of Appeals affirmed before the case reached this Court.

Reasoning

The core question was whether the government could use at trial words that agents had deliberately elicited from an indicted defendant in the absence of his retained lawyer. The Court relied on prior decisions protecting the right to counsel and held that, in a federal prosecution, using the defendant’s incriminating statements obtained after indictment and without his lawyer violated the Sixth Amendment right to counsel. The Court accepted that the police could continue investigating the suspected ring, but drew the line at using those particular statements as evidence. The Court did not decide the separate Fourth Amendment (search/surveillance) argument.

Real world impact

The Court reversed the convictions that rested on the challenged testimony and barred use of such statements at trial going forward. Prosecutors cannot rely on incriminating words deliberately elicited after formal charges if the defendant’s lawyer was not present. This limits use of cooperating co-defendants and secret recordings made after indictment and may require prosecutors to build cases differently.

Dissents or concurrances

Justice White dissented, warning the new rule would exclude voluntary, reliable evidence, hamper law enforcement efforts, and have broad consequences beyond this specific case.