## Facts

- Tyrone Patterson was indicted in Illinois for murder arising from a Chicago shooting.
- While in custody and after learning of the indictment, Patterson asked who else had been charged and began making statements implicating himself and others.
- An officer stopped him, provided a Miranda waiver form, advised him of his rights, and Patterson read, initialed each warning, and signed the waiver.
- Patterson then gave an inculpatory oral account admitting involvement in the killing.
- Later, an assistant state’s attorney again reviewed the Miranda warnings, confirmed Patterson understood them, obtained his agreement to speak, and received additional incriminating statements.
- Patterson moved to suppress the post-indictment statements as obtained in violation of his right to counsel; the trial court denied suppression, the statements were admitted, and he was convicted.
- The Illinois Supreme Court affirmed, holding that the Miranda warnings were sufficient; the U.S. Supreme Court granted review.

## Issues

1. Whether post-indictment, police-initiated custodial questioning without counsel violates the Sixth Amendment when the accused has not requested counsel.
2. Whether standard Miranda warnings can support a knowing and intelligent waiver of the Sixth Amendment right to counsel after adversary proceedings have begun.
3. Whether the Sixth Amendment requires warnings or waiver standards materially different from Miranda in the post-indictment interrogation setting.

## Decision

- The Court affirmed the conviction and admission of Patterson’s statements.
- Post-indictment questioning did not violate the Sixth Amendment because Patterson did not request counsel and validly waived his right to counsel.
- Standard Miranda warnings sufficiently informed Patterson of the right to have counsel present and the consequences of speaking, permitting a knowing and intelligent waiver.
- Police are not categorically barred from initiating interrogation after indictment when the accused has not invoked the right to counsel.

## Legal Principles

- The Sixth Amendment right to counsel attaches upon the initiation of adversary judicial proceedings, but it may be waived.
- A valid Sixth Amendment waiver requires that the accused be sufficiently aware of the right to have counsel present and of the likely consequences of foregoing counsel.
- In custodial interrogation after indictment, Miranda warnings generally convey the substance of the Sixth Amendment right to counsel and the risk that statements may be used against the accused.
- Restrictions on further police-initiated questioning apply when the accused has invoked the right to counsel; absent such a request, a properly warned and voluntary waiver permits interrogation.

## Conclusion

The Court held that Miranda warnings and a signed waiver can establish a knowing and intelligent waiver of the Sixth Amendment right to counsel during post-indictment custodial interrogation, and that police may initiate questioning so long as the accused has not requested counsel and the waiver is valid.


Patterson v. Illinois, 487 U.S. 285 (1988)