Edwards v. Arizona

by:

Following is the case brief for Edwards v. Arizona, Supreme Court of the United States, (1981)

Case summary for Edwards v. Arizona:

  • After receiving a Miranda warning and invoking his right to counsel, Edwards was transferred to a correctional facility.
  • The next day, a guard told Edwards that he must talk to the police, so when officers re-initiated questioning, Edwards responded with incriminating statements.
  • The statements were used against Edwards at trial and in response, he appealed his convictions claiming that his Fifth Amendment rights were violated.
  • The Court held that since the police re-initiated questioning without Edwards’ attorney present, and the state court erroneously applied the appropriate valid waiver standard, Edwards’ Fifth Amendment rights were violated.

Edwards v. Arizona Case Brief

Statement of the facts:

Subsequent to his arrest, Robert Edwards was taken into custody for robbery and murder. Officers read Edwards his Miranda rights. In response, Edwards answered a few questions, which resulted in no incriminating statements, and invoked his right to have an attorney present. The next day while in jail, two officers came to visit Edwards. Despite Edwards’ resistance, a guard required Edwards to speak with them and Edwards answered a few more questions which yielded incriminating statements. At trial, Edward’s incriminating statements were admitted despite objections.

Procedural History:

The state supreme court held that though Edwards had initially invoked his Fifth Amendment rights, they were later waived when the officers asked questions and Edwards voluntarily responded. Edwards petitioned to the Supreme Court of the United States, which granted certiorari.

Rule of Law or Legal Principle Applied:

Once a suspect invokes his Fifth Amendment right to either have an attorney present or remain silent during a custodial interrogation, the interrogation must stop.

Issue and Holding:

After a suspect has been provided with their Miranda warning and in response invokes his right to counsel, are incriminating statements made to officers subsequent to re-initiating communication admissible?  No.

Judgment:

The Court reversed the lower court’s judgment.

Reasoning:

The Court held that a suspect does not waive his Fifth Amendment rights when he responds to further questioning after invoking his right to counsel. Once this right is raised, officers must cease the interrogation until the suspect’s attorney is present. If the suspect is the first to initiate communications with officers and the communication results in disclosing incriminating information, the statements may be introduced at trial.

The Court held that in order for a valid waiver to occur, it must be both voluntary and knowingly.

Here, the state court did not consider the facts and circumstances surrounding the case to establish whether or not Edwards waived his right to counsel.  As a result, Edwards’ conviction is not sound.

Concurring or Dissenting opinion:

Concurring (Powell):

After receiving a Miranda warning and invoking the right to counsel, the question regarding whether or not a waiver occurred must be determined by the totality of the circumstances.  Looking at who initiated the communication is only one factor to consider in such a determination.

Significance:

This case points out the importance behind invoking the Fifth Amendment. Once invoked, questioning must cease.

Student Resources:

https://www.law.cornell.edu/supremecourt/text/451/477
https://supreme.justia.com/cases/federal/us/451/477/case.html