Montejo v. Louisiana

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Following is the case brief for Montejo v. Louisiana, 556 U.S. 778 (2009)

Case Summary of Montejo v. Louisiana:

  • Montejo was automatically provided an attorney at his first court proceeding in connection with a murder.  Police subsequently asked Montejo to assist in finding the murder weapon.  During the excursion, he wrote a letter of apology to the murder victim’s wife.
  • Montejo was convicted a trial.  On appeal, he claimed his letter should have been suppressed based on Michigan v. Jackson, which forbids police from questioning someone who requests counsel at a court proceeding.
  • The Louisiana Supreme Court affirmed the conviction, noting that Montejo never asked for counsel; counsel was automatically provided.
  • The U.S. Supreme Court vacated the judgment.  The Court overruled Jackson as unworkable and unnecessary given other constitutional protections already in place.  The Court also remanded to allow Montejo to seek suppression on another theory.

Montejo v. Louisiana Case Brief

Statement of the Facts:

Jesse Montejo was arrested in 2002, in connection with robbery and murder.  Montejo waived his Miranda rights and gave inconsistent accounts of his involvement in the crime.  Several days later, he was brought to court for a required preliminary hearing.  At that hearing, the court assigned Montejo an attorney, which is an automatic process in Louisiana for indigent defendants.

Later that same day, police officers asked Montejo if he would accompany them to find the murder weapon.  The officers read Montejo his Miranda rights.  Montejo agreed to go with the officers.  During the excursion, Montejo wrote the murder victim’s wife a letter of apology.  The letter of apology was entered into evidence against Montejo over his objection.

Procedural History:

  • Montejo was ultimately convicted at trial of first-degree murder and sentenced to death.
  • On appeal, Montejo argued that the letter of apology should have been suppressed under Michigan v. Jackson, 475 U.S. 625 (1986) (holding that police cannot initiate interrogation once a defendant invokes his right to counsel at a court proceeding).
  • The Louisiana Supreme Court affirmed the conviction and sentence.  It found that Jackson did not apply because Montejo never invoked his right to counsel. Rather, an attorney was simply appointed for him.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Is Michigan v. Jackson, which forbids police from initiating interrogation once a defendant has requested counsel at a court proceeding, still good law?  No.

Judgment:

The judgment of the Louisiana Supreme Court is vacated and remanded for further proceedings consistent with the U.S. Supreme Court’s opinion.

Rule of Law or Legal Principle Applied:

Because criminal defendants have sufficient Sixth Amendment protection from police badgering in the Court’s Miranda, Edwards, and Minnick decisions, the rule that police cannot initiate interrogations once a defendant requests counsel at a court proceeding is no longer viable.

Reasoning:

  • The litigants’ theories on both sides do not make Jackson workable.

The Louisiana Supreme Court found that a defendant must affirmatively assert his right to counsel for Jackson to apply.  That conclusion is not workable because in many jurisdictions, counsel is automatically provided to an indigent defendant without the defendant having to ask for it.  Thus, there would be confusion in those jurisdictions as to whether Jackson applies.  Conversely, Montejo contends that Jackson should always apply, even when counsel is automatically provided. That conclusion is also not workable because it is not connected to the reasoning of the Jackson case.

  • Jackson must be overruled.

In sum, Jackson must be overruled.  Stare decisis does not require following Jackson as precedent because (i) the precedent is not that old; (ii) there is little reliance on the decision; and (iii) the marginal benefits of the decision are outweighed by its negative impact on the truth-seeking function of the criminal justice system.  The Fifth and Sixth Amendment safeguards in the Miranda, Edwards, and Minnick decisions more than sufficiently protect from police trying to make a defendant waive his right to counsel.

  • Because the legal landscape has changed, Montejo can pursue an alternate theory of suppression.

Given that Jackson is now overruled, Montejo should be allowed the opportunity to demonstrate the he could have his letter suppressed under another theory.  Accordingly, the case is remanded for Montejo to be afforded that opportunity.

Concurring and Dissenting Opinions:

Concurring Opinion (Alito):

Based on opinions in other Court cases, the dissenting justices seem to have a shifting view of stare decisis.  Stare decisis, however, should be applied even-handedly in the development of legal principles.

Dissenting Opinion (Stevens):

Rather than reverse the Louisiana Supreme Court’s decision, the Court, without any proof that Jackson causes any harmful outcomes, decides to overrule Jackson.  It does so by misinterpreting the Jackson decision and undervaluing the principle of stare decisis.

Dissenting Opinion (Breyer):

The principles of stare decisis bind the Court in this case.  Jackson should not have been overruled.

Significance:

The significance of Montejo v. Louisiana lies in the debate over stare decisis.  The extent to which the Court should adhere to precedent is in stark relief in the Court’s decision to overrule Jackson, and Justice Stevens’s and Breyer’s dissenting opinions to not overrule it.

Student Resources:

https://supreme.justia.com/cases/federal/us/556/778/opinion.html

https://www.oyez.org/cases/2008/07-1529