Patterson v. Illinois
487 U.S. 285 (1988)
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Rule of Law:
An accused who is admonished with the warnings prescribed in Miranda v. Arizona has been sufficiently apprised of the nature of their Sixth Amendment right to counsel, and of the consequences of abandoning those rights, such that a waiver of the right during post-indictment questioning is considered knowing and intelligent.
Facts:
- Patterson, a member of the 'Vice Lords' street gang, was involved in a fight that resulted in the death of James Jackson.
- After being arrested and read his Miranda rights, Patterson gave a statement about an initial fight but denied any knowledge of Jackson's death.
- Two days later, a Cook County grand jury indicted Patterson for the murder of James Jackson.
- After the indictment, Police Officer Michael Gresham informed Patterson that he had been charged with murder and was being transferred.
- Patterson asked a question about the indictment, at which point Gresham interrupted him and administered a full set of Miranda warnings.
- Patterson initialed each warning, signed a waiver form, and then gave a detailed, lengthy statement confessing his involvement in the murder.
- Later the same day, an Assistant State’s Attorney again administered Miranda warnings, and Patterson provided a second inculpatory statement.
Procedural Posture:
- Patterson filed a pretrial motion in the Illinois trial court to suppress his post-indictment statements.
- The trial court denied the motion to suppress.
- Following a jury trial, Patterson was convicted of murder.
- Patterson appealed his conviction to the Illinois Supreme Court, arguing that his waiver of his Sixth Amendment right to counsel was not knowing and intelligent.
- The Illinois Supreme Court, as the state's highest court, affirmed the conviction.
- The United States Supreme Court granted Patterson's petition for a writ of certiorari.
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Issue:
Does administering Miranda warnings to an indicted defendant suffice to obtain a knowing and intelligent waiver of their Sixth Amendment right to counsel for the purpose of post-indictment interrogation?
Opinions:
Majority - Justice White
Yes. An accused's waiver of their Sixth Amendment right to counsel during post-indictment questioning is knowing and intelligent so long as they have been made aware of their rights through the standard Miranda warnings. The Miranda warnings convey the sum and substance of the Sixth Amendment right by informing the accused of the right to consult with an attorney, to have an attorney present during questioning, and to have one appointed if they cannot afford one. The warnings also make the accused aware of the primary consequence of waiving this right: that any statement made can be used against them in court. The court rejected the argument that the Sixth Amendment right to counsel is 'superior' to the Fifth Amendment right, finding that the pragmatic purpose of counsel at the questioning stage—to advise the accused on whether to speak to police—is substantially the same pre- and post-indictment, and therefore the same waiver standard applies.
Dissenting - Justice Blackmun
No. The Sixth Amendment mandates that once formal adversary proceedings have commenced, a defendant cannot be subject to further interrogation by authorities until counsel has been made available, unless the accused initiates the communication. The dissent argues that the majority is incorrect to equate a post-indictment accused with a pre-indictment suspect. The Constitution does not permit the prosecution to take advantage of the gap between the formal commencement of proceedings and the actual appointment of counsel for the defendant.
Dissenting - Justice Stevens
No. Warnings offered by an adversary—the police or prosecutor—cannot provide a sufficient basis for a valid waiver of the Sixth Amendment right to counsel after formal proceedings have begun. The dissent argues that the indictment fundamentally alters the relationship between the state and the accused, solidifying their adversary positions. It is unethical and unfair for a prosecutor or their agents to conduct a private interview with an unrepresented defendant, as they cannot provide the neutral legal advice required for a knowing and intelligent waiver of the 'dangers and disadvantages of self-representation.' Miranda warnings are a form of legal advice that is improper when given by an adversary and are insufficient to inform the accused of the full scope of an attorney's potential role post-indictment, such as examining the indictment or negotiating a plea.
Analysis:
This decision harmonizes the waiver standards for the Fifth and Sixth Amendment rights to counsel in the specific context of post-indictment interrogation, simplifying the procedure for law enforcement. By holding that standard Miranda warnings are sufficient, the Court rejected the view that the Sixth Amendment requires a more rigorous or detailed waiver procedure once formal charges are filed. This outcome prioritizes a pragmatic assessment of counsel's role at a specific stage over a hierarchical view of constitutional rights, though critics argue it dilutes the unique protections intended by the Sixth Amendment once the defendant becomes an official 'accused' in an adversary system.
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