Facts
- Raymond Levi Cobb was arrested in 1994 on an unrelated matter and confessed to burglarizing a home while denying knowledge of a missing woman and child from that residence.
- Cobb was indicted for burglary, and counsel was appointed for him on that charge.
- In 1995, Cobb told his father he had killed the missing woman and child; the father notified police.
- While in custody, Cobb received Miranda warnings, waived his rights, and confessed to the murders.
- Cobb was indicted for capital murder, convicted in Texas state court, and sentenced to death.
- On appeal, Cobb sought suppression of the murder confession, arguing his Sixth Amendment right to counsel had attached through the burglary indictment and appointment of counsel.
- The Texas Court of Criminal Appeals reversed, holding the right to counsel for the charged offense extended to other offenses that were very closely related factually.
- The U.S. Supreme Court granted review.
Issues
- Whether the Sixth Amendment right to counsel, once attached to a charged offense, bars police-initiated interrogation about uncharged crimes that are factually related to the charged offense without counsel present.
- How to define “offense” for Sixth Amendment offense-specificity, including whether the Blockburger elements test governs.
Decision
- The Supreme Court reversed the Texas Court of Criminal Appeals in a 5–4 decision.
- The Court held the Sixth Amendment right to counsel is offense-specific and does not extend merely because uncharged crimes are factually related to the charged offense.
- Applying the Blockburger elements test, the Court treated burglary and capital murder as separate offenses for Sixth Amendment purposes.
- Because Cobb received and waived Miranda rights, police could interrogate him about the murders despite counsel having been appointed on the burglary charge.
- Cobb’s confession to the murders was admissible.
Legal Principles
- The Sixth Amendment right to counsel attaches upon initiation of adversarial judicial proceedings for a particular charged offense and is limited to that offense.
- “Offense” for Sixth Amendment purposes is defined by the Blockburger elements test: two crimes are separate offenses if each requires proof of a fact the other does not.
- Police are not barred by the Sixth Amendment from initiating questioning about uncharged offenses that are separate under Blockburger, even if they arise from the same factual episode as a charged offense.
- Miranda warnings and a valid waiver remain the governing safeguards for custodial interrogation about uncharged offenses when the Sixth Amendment has attached only to different, charged offenses.
Conclusion
The Court held that appointment of counsel on a burglary charge did not prevent police, after Miranda warnings and waiver, from interrogating the defendant about factually related murders because the Sixth Amendment right to counsel is offense-specific and the crimes were separate under Blockburger.