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Keywords

lawyerprecedentappealtrialinterrogationrespondent

appealinterrogationrespondent

Related Cases

Arizona v. Roberson, 486 U.S. 675, 108 S.Ct. 2093, 100 L.Ed.2d 704, 56 USLW 4590

Facts

On April 16, 1985, the respondent was arrested at the scene of a burglary and advised of his rights under Miranda v. Arizona. He requested a lawyer before answering any questions, which was documented by the arresting officer. Three days later, while still in custody, a different officer, unaware of the earlier request for counsel, interrogated him about a different burglary and obtained an incriminating statement. The trial court suppressed this statement based on the precedent set in Edwards v. Arizona.

On April 19, 1985, while respondent was still in custody pursuant to the arrest three days earlier, a different officer interrogated him about a different burglary that had occurred on April 15. That officer was not aware of the fact that respondent had requested the assistance of counsel three days earlier.

Issue

Does the Edwards rule apply to police-initiated interrogation following a suspect's request for counsel in the context of a separate investigation?

The bright-line, prophylactic Edwards rule benefits the accused and the State alike.

Rule

The Edwards rule states that a suspect who has invoked his right to counsel is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication.

A suspect who has 'expressed his desire to deal with the police only through counsel is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication.'

Analysis

The court applied the Edwards rule to the facts of the case, emphasizing that the request for counsel must be honored regardless of the nature of the subsequent investigation. The court noted that the presumption of coercion remains in place when a suspect has requested counsel, and that the mere fact that the second interrogation was about a different offense does not negate the need for counsel. The court rejected the argument that the lack of knowledge by the second officer about the request for counsel justified the failure to honor it.

The nature and factual setting of this case do not compel an exception to the Edwards rule. The argument that the existence of separate investigations in itself precludes the type of badgering that led to the decision in Edwards is not persuasive.

Conclusion

The Supreme Court affirmed the decision of the Arizona Court of Appeals, holding that the Edwards rule applies to bar police-initiated interrogation following a suspect's request for counsel in the context of a separate investigation.

The judgment of the Arizona Court of Appeals is Affirmed.

Who won?

The respondent prevailed in the case because the court upheld the suppression of his incriminating statement, reinforcing the importance of the right to counsel.

The Arizona Court of Appeals affirmed the suppression order in a brief opinion, stating: 'In Routhier, as in the instant case, the accused was continuously in police custody from the time of asserting his Fifth Amendment right through the time of the impermissible questioning.'

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