Smith v. Illinois

Background

An 18-year-old man, Steven Smith, was arrested and taken to an interrogation room after an armed robbery. While the detectives were giving Miranda warnings, Smith said a woman had told him to “get my lawyer” and then replied, “Uh, yeah. I’d like to do that,” when told he had a right to a lawyer. The officers continued the warnings, asked whether he wanted to talk without a lawyer, and after further questioning Smith at one point said “I committed it.” He later again said he wanted a lawyer and the police stopped. Smith was convicted and the Illinois courts held his earlier words were ambiguous when viewed with his later answers, so officers did not have to stop questioning.

Reasoning

The Court addressed whether the suspect had invoked his right to counsel and whether later answers could be used to say the initial request was unclear. Relying on Miranda and Edwards, the Court held that if an accused clearly requests a lawyer, police must stop questioning and they may not use the accused’s post-request answers to claim the initial request was ambiguous. The Court reversed the Illinois Supreme Court. The decision is narrow: it does not settle all questions about when a request is ambiguous for other reasons.

Real world impact

The ruling means police must cease interrogation after a clear request for counsel. Officers cannot rely on what a suspect says afterward to retroactively undermine a clear request. The case was sent back for further proceedings consistent with this rule.

Dissents or concurrances

Justice Rehnquist (joined by two others) dissented, arguing the full short colloquy should be judged by the factfinder and that the officers properly completed the warnings and did not badger the suspect.