Michigan v. Jackson

1986-04-01

Headline: Court extends bright-line rule blocking police-initiated questioning after a defendant asks for a court-appointed lawyer at arraignment, preventing further interrogation until counsel is available

Holding: The Court held that when a defendant requests appointed counsel at arraignment, police may not initiate custodial questioning until counsel is available, and any waiver after such police initiation is invalid.

Real World Impact:

Prevents police from questioning defendants who asked for court-appointed lawyers until counsel arrives.
Makes Miranda warnings or a signed waiver insufficient after police-initiated post-arraignment interrogation.
Requires prosecutors to prove a valid waiver when counsel was requested at arraignment.

Topics: right to counsel, police interrogation, Miranda warnings, arraignment

Summary

Background

Two criminal defendants in Michigan — one accused of killing three railroad employees and another accused in a plot to kill a husband — were arraigned and asked the court to appoint lawyers for them. Police officers who had been involved in those investigations were present at the arraignments. Before the appointed lawyers reached the defendants, officers questioned each defendant in jail and obtained confessions, after first giving Miranda warnings.

Reasoning

The Court asked whether the Edwards rule (which bars police-initiated questioning after a suspect asks for counsel during custodial interrogation) also applies when a defendant requests appointed counsel at arraignment, a formal first court hearing. The majority held that the Sixth Amendment right to counsel attaches at arraignment, that protection is at least as strong as the Fifth Amendment protection, and that a defendant’s request for counsel prevents valid waiver of counsel for any later police-initiated interrogation until counsel is made available.

Real world impact

Because the State bears the burden of proving a valid waiver, the Court ruled these post-arraignment statements inadmissible when police initiated questioning after the request for counsel. The decision limits police ability to question accused people who have asked for appointed lawyers until counsel is present or the accused initiates further conversation.

Dissents or concurrances

Chief Justice Burger joined the judgment but urged reexamination of bright-line rules. Justice Rehnquist (joined by Powell and O’Connor) dissented, arguing Edwards should not be extended to the Sixth Amendment and that this prophylactic rule is unjustified.