Facts
- Two Michigan murder prosecutions were consolidated: Robert Bernard Jackson and Rudy Bladel.
- Each defendant was arraigned on homicide charges and requested appointment of counsel.
- Before either defendant had an opportunity to consult with counsel, police initiated custodial interrogation.
- Police provided Miranda warnings and obtained confessions from both defendants during the post-arraignment questioning.
- Trial courts denied suppression motions and admitted the confessions; both defendants were convicted.
- The Michigan Supreme Court held the confessions violated the Sixth Amendment and ordered suppression.
Issues
- Whether, after a defendant requests counsel at arraignment or a similar formal proceeding, police may initiate custodial interrogation and obtain a valid waiver of the defendant’s Sixth Amendment right to counsel.
Decision
- The Supreme Court affirmed the Michigan Supreme Court.
- The Court held that once a defendant asserts the right to counsel at arraignment or a similar proceeding, police may not initiate interrogation in the absence of counsel.
- Any waiver obtained during a police-initiated post-assertion interrogation is invalid, even if preceded by Miranda warnings.
- Chief Justice Burger concurred in the judgment.
- Justice Rehnquist dissented, joined by Justices Powell and O’Connor.
Legal Principles
- After a defendant asserts the Sixth Amendment right to counsel at arraignment or a comparable proceeding, police-initiated custodial interrogation is prohibited unless counsel is present or the defendant initiates communication.
- A waiver of the Sixth Amendment right to counsel obtained in a police-initiated interrogation following such an assertion is presumed invalid.
- The rule extended the prophylactic protection of Edwards v. Arizona to Sixth Amendment invocations made at arraignment.
- Miranda warnings and a signed waiver do not, by themselves, overcome the presumption of invalidity once the right to counsel has attached and been invoked in court.
- This decision was later overruled by Montejo v. Louisiana, which rejected the categorical presumption against police-initiated waivers after attachment of the Sixth Amendment right to counsel.
Conclusion
Michigan v. Jackson barred police from initiating interrogation after an arraigned defendant requested counsel and treated any resulting waiver as invalid, aiming to protect the accused’s decision to deal with the State through counsel once adversarial proceedings had begun.