Connecticut v. Barrett
479 U.S. 523 (1987)
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Rule of Law:
A suspect's statement that they will not provide a written statement without counsel present, but are willing to speak with police, constitutes a limited and unambiguous invocation of the right to counsel that does not require the suppression of subsequent oral statements.
Facts:
- In the early morning of October 24, 1980, William Barrett was arrested as a suspect in a sexual assault.
- Upon arrival at the police station, an officer advised Barrett of his Miranda rights.
- Barrett signed an acknowledgment that he received the warnings and stated he would not give the police any written statements but had no problem talking about the incident.
- Approximately 30 minutes later, police again advised Barrett of his Miranda rights.
- Barrett again stated he understood, would not give a written statement unless his attorney was present, but would talk to the officers.
- Barrett then gave an oral statement admitting his involvement in the sexual assault.
- After a tape recorder malfunctioned, police advised Barrett of his rights a third time, and he repeated his position and then repeated his oral confession.
Procedural Posture:
- At a suppression hearing in the Connecticut trial court, the judge ruled Barrett's confession was admissible.
- Following a jury trial, Barrett was convicted of sexual assault, unlawful restraint, and possession of a controlled substance.
- Barrett appealed his conviction to the Connecticut Supreme Court.
- The Connecticut Supreme Court (the state's highest court) reversed the convictions, holding that Barrett had invoked his right to counsel for all purposes and his oral statements should have been suppressed.
- The State of Connecticut, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the decision of the Connecticut Supreme Court.
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Issue:
Does a suspect who tells police he is willing to make an oral statement but not a written one without counsel present thereby invoke his Fifth Amendment right to counsel for all purposes, requiring suppression of his subsequent oral statements under Edwards v. Arizona?
Opinions:
Majority - Chief Justice Rehnquist
No. A suspect’s invocation of the right to counsel can be limited to a specific context, and if police honor that limitation, subsequent statements made outside that context are admissible. The fundamental purpose of Miranda is to protect a suspect’s choice to speak or remain silent. Barrett made an unambiguous choice to speak, while limiting his request for counsel to the context of written statements. The police honored this limited invocation by not seeking a written statement. To interpret Barrett's limited request as a broad invocation for all purposes would be to disregard the ordinary meaning of his words. The fact that his decision might seem illogical to some does not vitiate its voluntariness, so long as he understood his rights, which the trial court found he did.
Concurring - Justice Brennan
The judgment is correct, but for different reasons. Barrett’s statement—that he would talk but not write without counsel—created ambiguity as to whether he truly understood that his oral statements could be used against him. Ordinarily, this ambiguity would militate against finding a knowing and intelligent waiver. However, the ambiguity was resolved in this case because Barrett himself testified at trial that he fully understood his Miranda rights. This subsequent testimony confirmed that his waiver of the right to silence for oral statements was voluntary, knowing, and intelligent, thereby making his oral confession admissible.
Dissenting - Justice Stevens
The Court should not have heard this case, but having done so, it erred in its conclusion. The writ of certiorari should be dismissed as improvidently granted because the facts are unique, there is no conflict among lower courts, and the state court was arguably providing more protection to a citizen than the Constitution requires. On the merits, the governing rule requires courts to give a broad, not narrow, interpretation to a defendant's request for counsel. Barrett's request for an attorney before signing a written statement was no less ambiguous than the request in Edwards v. Arizona and should have been construed as a general invocation of the right to counsel, requiring all interrogation to cease.
Analysis:
This decision refines the Edwards 'bright-line' rule by establishing that a suspect's invocation of the right to counsel can be limited in scope. It moves away from a presumption that any mention of counsel halts all interrogation, instead focusing on the plain meaning of the suspect's words. This holding allows law enforcement to continue questioning a suspect on matters for which the right to counsel has not been explicitly invoked. Consequently, it places a greater onus on suspects to be clear and unequivocal if they wish to cease all questioning, potentially narrowing the practical protections afforded by Miranda and Edwards for suspects who make qualified or ambiguous statements.
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