Facts
- Robert Edwards was arrested in Arizona on charges including robbery, burglary, and first-degree murder.
- After receiving Miranda warnings at the police station, Edwards stated he understood his rights and initially agreed to questioning.
- During questioning, Edwards denied involvement and sought to “make a deal,” then stated, “I want an attorney before making a deal.”
- Police stopped the interrogation and Edwards was taken to jail.
- The next morning, detectives went to the jail, initiated contact, and sought to question Edwards again without counsel present.
- Edwards initially resisted but was told he “had to talk” to the detectives; he then received fresh Miranda warnings and gave a confession.
- The trial court denied a motion to suppress, deemed the confession voluntary, and Edwards was convicted; the Arizona Supreme Court affirmed on a waiver theory.
Issues
- Whether a suspect who has invoked the right to counsel during custodial interrogation can be found to have waived that right merely by responding to later police-initiated questioning after renewed Miranda warnings.
- Whether admitting a confession obtained through police-initiated custodial interrogation after an unfulfilled request for counsel violates the Fifth Amendment, applicable to the States through the Fourteenth Amendment.
Decision
- The Supreme Court reversed the Arizona Supreme Court.
- The Court held that Edwards’s January 20 confession was inadmissible because police reinitiated custodial interrogation after Edwards invoked his right to counsel and before counsel was made available.
- The Court rejected the view that renewed Miranda warnings and Edwards’s subsequent responses, standing alone, established a valid waiver after invocation.
Legal Principles
- Once an accused invokes the right to have counsel present during custodial interrogation, a valid waiver of that right cannot be shown merely because the accused responds to police-initiated interrogation after being advised of Miranda rights again.
- After invocation, the accused is not subject to further interrogation until counsel has been made available, unless the accused initiates further communication with police.
- A post-invocation waiver must be voluntary and also a knowing and intelligent relinquishment of the previously asserted right; voluntariness of the confession alone is insufficient to establish waiver.
- The rule operates as a safeguard for the Miranda-based Fifth Amendment right to counsel during custodial interrogation and places the burden on the State to show permissible recontact (counsel provided or suspect-initiated communication).
Conclusion
Because Edwards clearly requested counsel and police nevertheless initiated renewed custodial interrogation the next day without counsel present, his confession did not reflect a valid waiver of the invoked right to counsel and could not be admitted at trial.