Shea v. Louisiana
Headline: Fifth Amendment rule barring police questioning after a suspect requests a lawyer is applied retroactively, forcing courts to exclude such confessions in cases still on direct appeal when the rule was announced.
Holding: The Court held that the rule forbidding police-initiated interrogation after a suspect asks for a lawyer applies retroactively to convictions that were still on direct appeal when Edwards was decided, so the petitioner gets Edwards’ protection.
- Allows exclusion of confessions taken after a suspect asked for a lawyer in pending appeals.
- Requires courts to apply Edwards to cases not yet final when Edwards was announced.
- May lead to new trials or suppression of evidence in affected state prosecutions.
Summary
Background
Kevin Michael Shea, charged with two armed robberies in Louisiana, was arrested in July 1979. Police read him his Miranda rights and he said he would not speak until he had a lawyer. The next day a detective returned, again read Miranda rights, Shea signed a card, and then confessed. At trial in 1980 the confession was admitted and Shea was convicted. On appeal the Louisiana Supreme Court found an Edwards violation but refused to apply Edwards retroactively to his case.
Reasoning
The Supreme Court addressed whether Edwards v. Arizona — which bars police-initiated interrogation once a suspect asks for counsel — must be applied to cases that were still on direct review when Edwards was decided. Relying on United States v. Johnson, the Court said new constitutional rules generally apply to convictions that are not yet final when the rule is announced. The Court reversed the Louisiana decision and held that Shea was entitled to the benefit of Edwards because his case was pending on direct appeal when Edwards was decided.
Real world impact
The ruling requires courts to give Edwards protection to defendants whose convictions were not final when Edwards was announced. In practice, confessions obtained after a suspect asked for a lawyer and was then re-questioned by police may be excluded in such pending appeals. The case is returned to the Louisiana Supreme Court for further proceedings consistent with this decision, potentially leading to new trials or suppression of the confession.
Dissents or concurrances
Several Justices dissented, arguing retroactive application imposed heavy costs on States and that treating direct appeals differently from final convictions was unjustified; they would have limited Edwards’ retroactivity.
Opinions in this case:
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