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Keywords

defendantattorneylawyerappealtrialtestimonyarraignment
defendantlawyerappealtestimonyarraignmentself-incriminationrespondent

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Michigan v. Harvey, 494 U.S. 344, 110 S.Ct. 1176, 108 L.Ed.2d 293, 58 USLW 4288

Facts

Following Harvey's arraignment on rape charges and the appointment of counsel, he expressed a desire to make a statement to police but was uncertain about speaking to his lawyer. A police officer informed him that he did not need to consult his attorney, leading Harvey to sign a waiver and provide a statement. During his trial, his testimony conflicted with this statement, prompting the prosecution to use it for impeachment. The Michigan Court of Appeals ruled the statement inadmissible, citing a violation of Harvey's Sixth Amendment rights.

Following respondent Harvey's arraignment on rape charges and the appointment of counsel for him, he told a police officer that he wanted to make a statement, but did not know whether he should talk to his lawyer.

Issue

Whether a statement taken in violation of the prophylactic rule established in Michigan v. Jackson can be used to impeach a defendant's testimony.

The question presented in this case is whether the prosecution may use a statement taken in violation of the Jackson prophylactic rule to impeach a defendant's false or inconsistent testimony.

Rule

A statement taken in violation of the Jackson prophylactic rule may be used to impeach a defendant's testimony, even though it cannot be used as substantive evidence.

We held that statements obtained in violation of that rule may not be admitted as substantive evidence in the prosecution's case in chief.

Analysis

The Supreme Court reasoned that the Jackson rule, which presumes a waiver of the Sixth Amendment right to counsel is invalid if obtained through police-initiated conversation, does not prevent the use of such statements for impeachment purposes. The Court drew parallels to prior rulings regarding the Fifth Amendment, where statements taken in violation of Miranda can be used for impeachment. The Court emphasized that allowing impeachment serves the interest of truth-seeking in trials.

There is no reason for a different result in a Jackson case, where the prophylactic rule is designed to ensure voluntary, knowing, and intelligent waivers of the Sixth Amendment right to counsel rather than the Fifth Amendment privilege against self-incrimination or 'right to counsel.'

Conclusion

The Supreme Court reversed the Michigan Court of Appeals' decision and remanded the case for further proceedings, allowing the use of Harvey's statement for impeachment.

The judgment of the Michigan Court of Appeals is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

Who won?

The State of Michigan prevailed in the Supreme Court, as the Court ruled that Harvey's statement could be used for impeachment despite the violation of his Sixth Amendment rights.

The State concedes that the police transgressed the rule of Jackson, which held that once a defendant invokes his Sixth Amendment right to counsel, any waiver of that right—even if voluntary, knowing, and intelligent under traditional standards—is presumed invalid if given in a police-initiated discussion.

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