Duckworth v. Eagan
492 U.S. 195 (1989)
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Rule of Law:
Miranda warnings do not require a specific formulation, and a warning that reasonably conveys a suspect's rights is constitutionally adequate, even if it includes a statement that appointed counsel will be provided 'if and when you go to court.'
Facts:
- On May 16, 1982, Gary Eagan contacted a Chicago police officer, claiming he had found the body of a stabbed woman but denying any involvement.
- When officers arrived at the scene with Eagan, the victim, who was still alive, identified Eagan, exclaiming, 'Why did you stab me?'
- The investigation was transferred to the Hammond, Indiana, Police Department.
- The next day, Hammond police questioned Eagan. Before questioning, they read him a waiver form stating he had the right to an attorney before and during questioning, but also that an attorney would be appointed 'if and when you go to court.'
- Eagan signed this form and provided an exculpatory story.
- Approximately 29 hours later, police interviewed Eagan again after reading him a second, different waiver form.
- After signing the second form, Eagan confessed to stabbing the woman.
- The following morning, Eagan led police to the knife used in the stabbing and to items of his clothing.
Procedural Posture:
- At trial in an Indiana state court, Eagan's confession was admitted into evidence over his objection.
- A jury convicted Eagan of attempted murder.
- The Indiana Supreme Court upheld the conviction on appeal.
- Eagan filed a petition for a writ of habeas corpus in the U.S. District Court for the Northern District of Indiana.
- The District Court denied the petition.
- Eagan appealed to the U.S. Court of Appeals for the Seventh Circuit, where he was the appellant and Duckworth was the appellee.
- A divided panel of the Seventh Circuit reversed the District Court's decision, finding the first warning constitutionally defective.
- The U.S. Supreme Court granted certiorari to review the decision of the Seventh Circuit.
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Issue:
Does a Miranda warning that advises a suspect that an appointed attorney will be provided 'if and when you go to court' render the warning constitutionally inadequate?
Opinions:
Majority - Chief Justice Rehnquist
No. A Miranda warning is not rendered constitutionally inadequate by including a statement that an attorney will be appointed 'if and when you go to court,' so long as the warning, in its totality, reasonably conveys the suspect's rights. The Court has never required a 'talismanic incantation' or the exact formulation of words from the Miranda opinion. The inquiry is simply whether the warnings reasonably convey the suspect's rights to have an attorney present before and during questioning. The 'if and when you go to court' language accurately described the Indiana procedure for appointing counsel and does not negate the clear statement that Eagan had a right to counsel before questioning. Miranda does not require that police have a 'station house lawyer' ready on call, only that they cease interrogation if a suspect who cannot afford an attorney requests one.
Dissenting - Justice Marshall
Yes. A warning that conditions the appointment of counsel on a future event like 'going to court' is constitutionally defective because it fails to clearly and unequivocally inform a suspect of the right to appointed counsel prior to interrogation. Such a caveat is confusing and misleading to a layperson, who might conclude that a lawyer is unavailable until after questioning is complete, thereby creating coercive pressure to speak without counsel. The fact that the warning accurately reflects state procedure is irrelevant, as state law cannot diminish a federal constitutional right. The majority's holding misinterprets both Miranda's requirement of an 'effective and express' warning and the Court's precedent in California v. Prysock, which cautioned against linking the right to appointed counsel to a future point in time.
Concurring - Justice O'Connor
This opinion concurs in the majority's judgment but argues on an alternative ground not reached by the majority. Justice O'Connor contended that the rationale of Stone v. Powell, which bars federal habeas corpus review of Fourth Amendment exclusionary rule claims if the state provided a full and fair opportunity to litigate them, should be extended to claims of Miranda violations. Miranda rights are prophylactic rules, not direct constitutional commands, and their enforcement via federal habeas review years after a conviction offers minimal deterrent value at a high cost to the finality of criminal judgments and principles of federalism. Therefore, federal courts should not entertain such claims on collateral review.
Analysis:
This decision represents a significant step in the Court's move away from a rigid, formalistic interpretation of Miranda warnings toward a more flexible, substantive standard. By holding that warnings need only 'reasonably convey' the required rights, the Court gives law enforcement more leeway in how they phrase the advisements. This makes it more difficult for defendants to succeed on claims of technical Miranda violations, shifting the focus from the precise wording used to the overall message communicated to the suspect. The decision solidifies the view that Miranda's requirements are prophylactic safeguards rather than constitutional rights in themselves.
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