Michigan v. Jackson
475 U.S. 625 (1986)
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Rule of Law:
Under the Sixth Amendment, if police initiate an interrogation after a defendant has asserted their right to counsel at an arraignment or similar proceeding, any waiver of the defendant's right to counsel for that police-initiated interrogation is invalid.
Facts:
- Respondent Bladel, a disgruntled former Amtrak employee, was suspected in the murder of three railroad employees.
- After being arrested, Bladel was formally arraigned, where he was indigent and requested that counsel be appointed for him.
- Three days after the arraignment but before Bladel's appointed law firm was notified, two police officers interviewed Bladel in jail and obtained a confession from him.
- Respondent Jackson was a participant in a plan to have a woman's husband killed.
- Jackson was arrested and, during his arraignment, requested that counsel be appointed for him.
- The morning after the arraignment, before Jackson had an opportunity to consult with counsel, two police officers obtained another statement from him.
- In both cases, the police officers who conducted the postarraignment interrogations had been present at the arraignments where the defendants requested counsel.
- Prior to the postarraignment interrogations, both Bladel and Jackson were advised of their Miranda rights and agreed to speak with the officers without counsel present.
Procedural Posture:
- In Bladel's case, the trial court admitted his postarraignment confession, and he was convicted. The Michigan Court of Appeals initially affirmed but later reversed. The prosecutor appealed to the Michigan Supreme Court.
- In Jackson's case, the trial court admitted his postarraignment statement, and he was convicted. The Michigan Court of Appeals affirmed his murder conviction. Jackson appealed to the Michigan Supreme Court.
- The Michigan Supreme Court consolidated the two cases.
- The Michigan Supreme Court held that the postarraignment statements in both cases were obtained in violation of the Sixth Amendment and should have been suppressed, reversing the lower court decisions.
- The State of Michigan (as petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the Michigan Supreme Court's decision.
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Issue:
Does the Sixth Amendment right to counsel prohibit police from initiating an interrogation of a defendant after that defendant has requested the assistance of counsel at their arraignment?
Opinions:
Majority - Justice Stevens
Yes. The Sixth Amendment prohibits police from initiating an interrogation of a defendant after the defendant has asserted their right to counsel at an arraignment. The reasons for prohibiting interrogation of an uncounseled defendant who has requested a lawyer are even stronger after formal charges have been filed than before. The Sixth Amendment guarantees an accused the right to rely on counsel as a 'medium' between them and the State once formal adversary proceedings have begun. The court presumes a defendant's request for counsel applies to all critical stages, including interrogation, and rejects the notion that a subsequent written waiver in a police-initiated interview can be valid. Knowledge of the request for counsel is imputed from the court to the police, as they are both actors of the State.
Dissenting - Justice Rehnquist
No. The Sixth Amendment right to counsel should not be protected by the prophylactic rule from Edwards v. Arizona. The Edwards rule was created to protect the Fifth Amendment right against self-incrimination from police badgering during custodial interrogation. The Sixth Amendment right to counsel, however, attaches automatically at a formal proceeding and does not depend on a request from the defendant. The majority's decision illogically creates a special protection only for those defendants who happen to explicitly request counsel, even though the right exists for all defendants once formal proceedings begin, making the request legally insignificant for the attachment of the right itself.
Concurring - Chief Justice Burger
Yes. While the expansion of 'bright-line' rules can lead to an absolutist and mechanical treatment of the law, stare decisis compels following the rule of Edwards v. Arizona in this context. This area of law, however, is leading to outcomes where more criminals go free because of police blunders. The subject calls for reexamination.
Analysis:
This decision established the 'Michigan v. Jackson rule,' which extended the Fifth Amendment prophylactic protections of Edwards v. Arizona to the Sixth Amendment context. By creating a bright-line rule, the Court provided defendants who had been formally charged with a powerful shield against police-initiated interrogations after they had requested counsel. This significantly strengthened a defendant's right to counsel post-arraignment, making it much more difficult for the state to obtain waivers and confessions. This bright-line rule stood for over two decades until it was expressly overturned by the Supreme Court in Montejo v. Louisiana, 556 U.S. 778 (2009).
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