Edwards v. Arizona

Supreme Court of United States
451 U.S. 477 (1981)

ELI5:

Rule of Law:

Once a suspect in custody has invoked their Fifth Amendment right to counsel, police may not re-initiate interrogation until counsel has been made available, unless the suspect themselves initiates further communication with the police. A suspect's response to police-initiated re-interrogation, even after being re-advised of their rights, does not constitute a valid waiver of the previously invoked right to counsel.

Facts:

A sworn complaint was filed against Edwards in Arizona state court charging him with robbery, burglary, and first-degree murder.
Edwards was arrested at his home, taken to the police station, and informed of his Miranda rights.
Edwards initially agreed to questioning and provided an alibi, but then sought to 'make a deal'.
After a brief, unsuccessful phone call to a county attorney, Edwards stated, 'I want an attorney before making a deal.'
Questioning immediately ceased, and Edwards was taken to the county jail.
The next morning, two different detectives came to the jail to question Edwards.
A detention officer told Edwards the detectives wanted to speak with him; Edwards replied that he did not want to talk to anyone, but the guard told him 'he had' to.
The detectives re-advised Edwards of his Miranda rights, played a portion of an accomplice's taped statement that implicated him, and Edwards then made an incriminating statement.

Procedural Posture:

Edwards was charged in Arizona state trial court.
Prior to trial, Edwards filed a motion to suppress his confession.
The trial court initially granted the motion to suppress but later reversed its ruling, finding the confession voluntary.
The confession was admitted at trial, and Edwards was convicted.
Edwards appealed to the Arizona Supreme Court, which is the state's highest court.
The Arizona Supreme Court affirmed the conviction, holding that Edwards had knowingly and voluntarily waived his right to counsel.
The U.S. Supreme Court granted certiorari to review the decision of the Arizona Supreme Court.

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Issue:

Does the Fifth Amendment, as applied to the states through the Fourteenth Amendment, prohibit police from re-initiating interrogation of a suspect in custody after that suspect has invoked their right to counsel?

Opinions:

Majority - Justice White

Yes. When an accused has invoked their right to have counsel present during custodial interrogation, a valid waiver of that right cannot be established by showing only that they responded to further police-initiated custodial interrogation. The Court held that once an accused expresses a desire to deal with the police only through counsel, they are not subject to further interrogation by the authorities until counsel has been made available, unless the accused themselves initiates further communication. The Arizona Supreme Court erred by applying a general voluntariness standard instead of the stricter standard required for waiving the right to counsel once it has been invoked. Edwards's statement was the result of police-initiated interrogation after he had clearly asserted his right to counsel, making the subsequent confession inadmissible.

Concurring - Chief Justice Burger

Yes, but on narrower grounds. The majority's creation of a new special rule for waiver is unnecessary. The traditional standard from Johnson v. Zerbst, which asks whether there was a voluntary, knowing, and intelligent waiver based on the totality of the circumstances, is sufficient. In this case, the key fact is that the detention officer told Edwards 'that he had to' speak with the detectives. This coercion rendered the subsequent waiver involuntary under the established standard, making the majority's new 'initiation' test superfluous.

Concurring - Justice Powell

Yes, the judgment should be reversed, but the majority's opinion and its new rule are unclear and potentially problematic. The Court's opinion seems to create a new per se rule focused on 'initiation,' which is an unnecessary addition to the established doctrine of waiver of counsel from Johnson v. Zerbst. The ultimate question should be whether there was a free and knowing waiver of counsel under all the circumstances, not a rigid inquiry into who started the conversation. While the police conduct here was clearly coercive and violated Edwards's rights, the majority's broad new rule may improperly restrict legitimate police communications in future, less clear-cut cases.

Analysis:

This decision establishes the 'Edwards rule,' a bright-line, prophylactic rule that strengthens the protections articulated in Miranda v. Arizona. It departs from a flexible 'totality of the circumstances' analysis for waiver once the right to counsel has been asserted, creating a more rigid standard. The ruling provides clear guidance to law enforcement: once a suspect asks for a lawyer, all police-initiated interrogation must cease until counsel is present. This significantly raises the bar for the prosecution to prove that a suspect waived their right to counsel after invoking it, shifting the critical inquiry to whether the suspect, not the police, reinitiated the dialogue.

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