Facts
Respondent Bladel
Respondent Rudy Bladel had been convicted of murdering three railroad employees at the Amtrak station in Jackson, Michigan, on December 31, 1978. [3]
Bladel, a disgruntled former employee, had been arrested three months later in Indiana and extradited to Michigan. He had agreed to talk to the police without counsel. At his arraignment he requested that counsel be appointed for him because he was indigent. The detective in charge of the investigation was present at the arraignment. A notice of appointment was then mailed to a law firm, but before the law firm received the notice, two police officers interviewed Bladel in the county jail and obtained a confession from him. Prior to that questioning, the officers had advised Bladel of his Miranda rights. Although Bladel had inquired about his representation several times since the arraignment, he was not told that a law firm had been appointed to represent him.
Bladel then objected to the admissibility of the confession but the trial court overruled his objection. He was convicted and sentenced to three life sentences to run consecutively. [4] On appeal from his conviction and sentence, Bladel challenged the confession. The Michigan Court of Appeals first rejected that challenge and affirmed the conviction, [5] but, after reconsideration in the light of a recent decision by the State Supreme Court, it reversed and remanded for a new trial. [6] The Michigan Supreme Court then granted the prosecutor's application for leave to appeal, and considered the case with respondent Jackson's appeal of his conviction. [7]
Respondent Jackson
Respondent Robert Bernard Jackson had been convicted of second-degree murder and conspiracy to commit second-degree murder after allegedly taking part in a wife's plan to have her husband killed on July 12, 1979. [8] He made a number of statements to police after his arrest but before his arraignment. During his arraignment, Jackson requested that counsel be appointed for him.
On the following morning, before he had an opportunity to consult with counsel, two police officers obtained another statement from Jackson to "confirm" that he was the person who had shot the victim. As was true of the prearraignment statements, the questioning was preceded by advice of his Miranda rights and Jackson's agreement to proceed without counsel being present.
The Michigan Court of Appeals held that Jackson's later statement was properly received in evidence. [9] Accordingly, it affirmed Jackson's conviction of murder, although it set aside the conspiracy conviction on unrelated grounds.
Michigan Supreme Court
The Michigan Supreme Court held that the postarraignment statements in both cases should have been suppressed.
The U.S. Supreme Court had held previously in Edwards v. Arizona , 451 U.S. 477 (1981), that an accused person in custody 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, exchanges, or conversations with the police. [10]
The Court of Appeals had distinguished the Edwards rule on the ground that Jackson's request for an attorney had been made at his arraignment, whereas Edwards' request had been made during a custodial interrogation by the police. Noting that the Sixth Amendment right to counsel attached at the time of the arraignments, the Michigan Supreme Court concluded that the Edwards rule,
applies by analogy to those situations where an accused requests counsel before the arraigning magistrate. Once this request occurs, the police may not conduct further interrogations until counsel has been made available to the accused, unless the accused initiates further communications, exchanges, or conversations with the police. . . . The police cannot simply ignore a defendant's unequivocal request for counsel. [11]
Aftermath
The holding in Michigan v. Jackson was narrowed later by the Court in McNeil v. Wisconsin , [18] which held that an accused's invocation of his Sixth Amendment right to counsel during a judicial proceeding does not constitute an invocation of the right to counsel derived by Miranda v. Arizona , [19] from the Fifth Amendment's guarantee against compelled self-incrimination. "Therefore, while a defendant who has invoked his Sixth Amendment right to counsel with respect to the offense for which he is being prosecuted may not waive that right, he may waive his Miranda–based right not to be interrogated about unrelated and uncharged offenses." [20] Also the Court held in Michigan v. Harvey [21] that evidence acquired in violation of Michigan v. Jackson could be used for impeachment purposes. [22]
Rudy Bladel was retried, found guilty and sentenced to three concurrent life sentences with no possibility of parole added to the sentence. [23] He died in Jackson, Michigan on November 15, 2006 of thyroid cancer. [24]
On March 27, 2009, the Supreme Court ordered lawyers in a pending case, Montejo v. Louisiana , (Docket No.07-1529), to file new briefs on whether the Court should overrule its decision in Michigan v. Jackson. [25] [26] [27] On May 26, 2009 the Supreme Court overruled Michigan v. Jackson through the Court's decision in Montejo v. Louisiana. [28]
In the United States, the Miranda warning is a type of notification customarily given by police to criminal suspects in police custody advising them of their right to silence and, in effect, protection from self-incrimination; that is, their right to refuse to answer questions or provide information to law enforcement or other officials. Named for the U.S. Supreme Court's 1966 decision Miranda v. Arizona, these rights are often referred to as Miranda rights. The purpose of such notification is to preserve the admissibility of their statements made during custodial interrogation in later criminal proceedings. The idea came from law professor Yale Kamisar, who subsequently was dubbed "The father of Miranda."
The Sixth Amendment to the United States Constitution sets forth rights related to criminal prosecutions. It was ratified in 1791 as part of the United States Bill of Rights. The Supreme Court has applied all but one of this amendment's protections to the states through the Due Process Clause of the Fourteenth Amendment.
Miranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the U.S. Supreme Court in which the Court ruled that the Fifth Amendment to the U.S. Constitution restricts prosecutors from using a person's statements made in response to interrogation in police custody as evidence at their trial unless they can show that the person was informed of the right to consult with an attorney before and during questioning, and of the right against self-incrimination before police questioning, and that the defendant not only understood these rights but also voluntarily waived them.
Escobedo v. Illinois, 378 U.S. 478 (1964), was a United States Supreme Court case holding that criminal suspects have a right to counsel during police interrogations under the Sixth Amendment. The case was decided a year after the court had held in Gideon v. Wainwright that indigent criminal defendants have a right to be provided counsel at trial.
Yale Kamisar was an American legal scholar and writer who was the Clarence Darrow Distinguished University Professor of Law Emeritus and Professor Emeritus of Law at the University of Michigan Law School. A "nationally recognized authority on constitutional law and criminal procedure", Kamisar is known as the "father of Miranda" for his influential role in the landmark U.S. Supreme Court decision in Miranda v. Arizona (1966).
McNeil v. Wisconsin, 501 U.S. 171 (1991), held that the right to counsel secured by the Sixth Amendment and the right to counsel protected by Miranda v. Arizona are separate and distinct, such that invoking one does not implicitly invoke the other.
Massiah v. United States, 377 U.S. 201 (1964), was a case in which the Supreme Court of the United States held that the Sixth Amendment to the United States Constitution prohibits the government from eliciting statements from the defendant about themselves after the point that the Sixth Amendment right to counsel attaches.
Oregon v. Bradshaw, 462 U.S. 1039 (1983), applied the rule first announced in Edwards v. Arizona (1981) and clarified the manner in which a suspect may waive his right under Miranda v. Arizona (1966) to have counsel present during interrogation by the police.
Spano v. New York, 360 U.S. 315 (1959), represented the Supreme Court's movement away from the amorphous voluntariness standard for determining whether police violated due process standards when eliciting confessions and towards the modern rule in Miranda v. Arizona. In Spano, the Court focused less on factors such as meals provided to the accused and more on whether the accused had access to legal counsel.
Indiana v. Edwards, 554 U.S. 164 (2008), was a United States Supreme Court case in which the Court held that the standard for competency to stand trial was not linked to the standard for competency to represent oneself.
Montejo v. Louisiana, 556 U.S. 778 (2009), is a 5–4 decision by the United States Supreme Court that overruled the Court's decision in Michigan v. Jackson. The case concerned the validity of a defendant's waiver of his right to counsel during a police interrogation. In reversing Jackson, the Court said such a waiver was valid.
Edwards v. Arizona, 451 U.S. 477 (1981), is a decision by the United States Supreme Court holding that once a defendant invokes his Fifth Amendment right to counsel, police must cease custodial interrogation. Re-interrogation is only permissible once defendant's counsel has been made available to him, or he himself initiates further communication, exchanges, or conversations with the police. Statements obtained in violation of this rule are a violation of a defendant's Fifth Amendment rights.
Berghuis v. Thompkins, 560 U.S. 370 (2010), is a landmark decision by the Supreme Court of the United States in which the Court considered the position of a suspect who understands their right to remain silent under Miranda v. Arizona and is aware that they have the right to remain silent, but does not explicitly invoke or waive the right.
Brewer v. Williams, 430 U.S. 387 (1977), is a decision by the United States Supreme Court that clarifies what constitutes "waiver" of the right to counsel for the purposes of the Sixth Amendment. Under Miranda v. Arizona, evidence obtained by police during interrogation of a suspect before he has been read his Miranda rights is inadmissible. Here, however, the defendant had been indicted in court and had asserted his desire to have counsel, thus his Sixth Amendment right to counsel had attached. At issue was whether a voluntary admission of incriminating facts in response to police statements made while the defendant was in custody and outside the presence of his lawyer constituted a waiver of this right to counsel.
The United States Constitution contains several provisions regarding the law of criminal procedure.
The Assistance of Counsel Clause of the Sixth Amendment to the United States Constitution provides: "In all criminal prosecutions, the accused shall enjoy the right...to have the Assistance of Counsel for his defence."
In re Oliver, 333 U.S. 257 (1948), was a decision by the United States Supreme Court involving the application of the right of due process in state court proceedings. The Sixth Amendment in the Bill of Rights states that criminal prosecutions require the defendant "... to be informed of the nature and cause of the accusation...and to have the Assistance of Counsel for his defence." In this case, a witness in a Michigan grand jury hearing was convicted and sentenced to jail without either notice or attorney assistance.
Lafler v. Cooper, 566 U.S. 156 (2012), was a United States Supreme Court case in which the Court clarified the Sixth Amendment standard for reversing convictions due to ineffective assistance of counsel during plea bargaining. The Court ruled that when a lawyer's ineffective assistance leads to the rejection of a plea agreement, a defendant is entitled to relief if the outcome of the plea process would have been different with competent advice. In such cases, the Court ruled that the Sixth Amendment requires the trial judge to exercise discretion to determine an appropriate remedy.
Howes v. Fields, 565 U.S. 499 (2012), was a decision by the U.S. Supreme Court that an interrogation of a prisoner was not a custodial interrogation per se, and certainly it was not "clearly established federal law" that it was custodial, as would be required by the Antiterrorism and Effective Death Penalty Act (AEDPA). Instead, the Court said, whether the interrogation was custodial depended on the specific circumstances, and moreover, in the particular circumstances of this case, it was not custodial. This decision overturned the rule of the Sixth Circuit, and denied the prisoner's habeas corpus petition.
Iowa v. Tovar, 541 U.S. 77 (2004), was a unanimous decision of the Supreme Court of the United States that clarified how well-informed a defendant had to be to waive their right to counsel under the Sixth Amendment. The defendant in this case had waived his right to counsel and pled guilty to drunk driving, and then had been convicted of drunk driving twice more, with sentences increasing as his convictions piled up. He argued that the judge in the first case had not explained that multiple drunk driving convictions would lead to more severe sentences, so his waiver of counsel had been invalid. The Supreme Court disagreed, saying that the judge's warnings had been adequate, and the defendants' waiver was "knowing, voluntary, and intelligent."
