Two step interrogation Flashcards
Edwards v Arizona
Facts
Edwards v. Arizona revolves around the post-arrest interrogation of Robbery, Burglary, and First-Degree Murder suspect, Edwards. After his arrest, Edwards was informed of his Miranda rights, to which he initially complied and provided a taped alibi. However, upon mention of making a deal, and after a failed attempt to call a county attorney, Edwards requested an attorney before making any deal. This led to the cessation of his interrogation. The following morning, without Edwards’ request and despite his initial reluctance, he was brought to two detectives. After being read his Miranda rights again and listening to part of a taped statement from an alleged accomplice, Edwards made an incriminating statement, not on tape, implicating himself in the crime. Prior to trial, Edwards sought to suppress this confession, arguing a violation of his Miranda rights as he had invoked his right to counsel.
Issue
The central issue in Edwards v. Arizona was whether the Fifth, Sixth, and Fourteenth Amendments require the suppression of a post-arrest confession obtained after the defendant had invoked his right to consult counsel before further interrogation.
Holding
The United States Supreme Court held that once an accused has invoked their right to counsel, any waiver of the right to counsel during subsequent police-initiated interrogation cannot be considered valid unless the accused himself initiates further communication or conversations with the police. Therefore, the confession obtained from Edwards on January 20, without counsel present and after he invoked his right to counsel, violated his rights under the Fifth and Fourteenth Amendments as construed in Miranda v. Arizona. As a result, the judgment of the Arizona Supreme Court was reversed.
Reasoning
The Court’s reasoning was rooted in the principles established in Miranda v. Arizona. It emphasized that once an individual has invoked their right to counsel, all police-initiated interrogation must cease until an attorney is present. The Court clarified that a valid waiver of the right to counsel, once invoked, cannot be established merely by the accused’s compliance with further police-initiated interrogation. Edwards’ confession was deemed inadmissible as it was not a result of his initiation but rather the result of police-initiated interrogation without counsel present, following his explicit invocation of his right to counsel. This decision further reinforced the procedural safeguards intended to protect the Fifth Amendment right against compelled self-incrimination, especially in custodial settings. The Court also differentiated between voluntary admission and knowing, intelligent waiver of rights, underscoring the necessity of the latter in cases where
QUestioning has to stop when
- must cease until attorney is present
2.
waiver of counsel
must be voluntary and constitute a knowing
Maryland v Shatzer
Facts
In August 2003, Michael Shatzer, Sr., who was serving a sentence for an unrelated child-sexual-abuse offense, was investigated for sexually abusing his 3-year-old son. Detective Shane Blankenship interviewed Shatzer, who invoked his right to an attorney, ending the interview. The investigation was closed shortly thereafter. Over two years later, in March 2006, Detective Paul Hoover reopened the investigation based on more specific allegations. Shatzer was interviewed again, waived his Miranda rights, and made incriminating statements. He did not request an attorney until after failing a polygraph test. Shatzer moved to suppress his statements under Edwards v. Arizona, arguing his right to counsel had been violated due to the previous invocation in 2003.
Issue
Does a break in custody end the presumption of involuntariness for statements made by a suspect who has previously invoked his right to counsel, as established in Edwards v. Arizona?
Holding
Yes, a break in custody can end the presumption of involuntariness established in Edwards v. Arizona, allowing for a subsequent waiver of Miranda rights and lawful interrogation. The Supreme Court reversed the decision of the Court of Appeals of Maryland.
Reasoning
Justice Scalia, writing for the Court, clarified that the Fifth Amendment’s protection against compelled self-incrimination is not violated if there is a sufficient break in custody that diminishes the inherently compelling pressures of custodial interrogation. The Court introduced a 14-day break-in-custody rule, reasoning that such a period allows a suspect to consult with friends, family, and possibly an attorney, thus dissipating the coercive effects of custody. This rule aims to provide law enforcement with a clear guideline for when it is permissible to reinitiate interrogation after a suspect has previously invoked the right to counsel. The Court found that Shatzer’s return to the general prison population for over two years constituted a break in custody, significantly reducing the pressures that Edwards seeks to mitigate. Consequently, Shatzer’s 2006 waiver of Miranda rights was deemed valid, and his statements were admissible, emphasizing the decision’s practical implications for law enforcement and judicial efficiency while safeguarding against compelled confessions.
Harris v New York
Facts
In Harris v. New York, the Supreme Court dealt with a case where the petitioner, Harris, was charged by the State of New York in a two-count indictment with selling heroin to an undercover police officer on two occasions. At trial, the prosecution’s chief witness was the undercover officer who testified about the two sales. Harris took the stand in his own defense, admitting to knowing the officer and to making a sale, but claimed it was baking powder as part of a scheme to defraud the purchaser. During cross-examination, the prosecution sought to impeach Harris’s credibility by asking about statements he made to the police following his arrest—statements that contradicted his testimony at trial. These statements were made without the warnings required by Miranda v. Arizona, rendering them inadmissible in the prosecution’s case in chief but were used for impeachment purposes. The trial judge instructed the jury that these statements could only be considered for assessing Harris’s credibility.
Issue
The issue before the Supreme Court was whether statements made by a defendant to police that are inadmissible in the prosecution’s case in chief under Miranda v. Arizona due to the lack of Miranda warnings can be used to impeach the defendant’s credibility if they take the stand and testify in their own defense.
Holding
The Supreme Court held that the petitioner’s credibility could indeed be impeached by the use of his earlier conflicting statements made to the police, even though these statements were obtained without the Miranda warnings and thus were inadmissible in the prosecution’s case in chief.
Reasoning
The Court reasoned that the Miranda decision, which requires that certain warnings be given to a suspect before any statements made during custodial interrogation can be admissible in the prosecution’s case, does not mean that such statements are inadmissible for all purposes. Drawing an analogy to Walder v. United States, which allowed inadmissible evidence to be used for impeachment purposes, the Court found no significant difference in principle that would preclude applying the same reasoning to statements obtained in violation of Miranda. The Court emphasized that allowing a defendant to perjure themselves without the risk of impeachment with their prior inconsistent statements would be a perversion of the rights afforded by the Constitution. It was important to the Court that the impeachment process serves as a valuable tool in assessing a defendant’s credibility and that sufficient deterrence against improper police conduct is maintained by making the evidence inadmissible in the prosecution’s main case. Thus, the use of such statements for impeachment respects the balance between a defendant’s rights and the integrity of the judicial process.
New York v Quarles
Facts
On September 11, 1980, around 12:30 a.m., Officer Frank Kraft and Officer Sal Scarring were patrolling in Queens, New York, when they were approached by a woman who reported she had been raped by a man matching Benjamin Quarles’ description. The man, she said, had entered a nearby supermarket and was armed. Officer Kraft located Quarles in the supermarket, pursued him, and after losing sight of him momentarily, found him again and conducted a frisk, discovering an empty shoulder holster. Quarles, upon being asked and before being read his Miranda rights, indicated where the gun was located. The trial court suppressed the gun and Quarles’ statements about its location and ownership due to the lack of Miranda warnings prior to the questioning.
Issue
The legal issue is whether there exists a “public safety” exception to the requirement that police officers must give Miranda warnings before questioning a suspect in custody, specifically in situations where the immediate concern is to locate a dangerous weapon that could pose a threat to public safety.
Holding
The Supreme Court held that there is a “public safety” exception to the Miranda requirement. This means that if the police’s questions are reasonably prompted by a concern for public safety, such as locating an abandoned weapon, the answers obtained can be admitted into evidence even if the suspect was not provided Miranda warnings before being questioned.
Reasoning
The Court reasoned that the Miranda decision, while aimed at protecting the Fifth Amendment privilege against self-incrimination during custodial interrogation, did not intend to hinder the police’s ability to act swiftly in situations that pose an immediate danger to public safety. The Court recognized an exigent-circumstances exception similar to exceptions under the Fourth Amendment, where the needs of law enforcement justify a warrantless search due to compelling circumstances. In the case of Quarles, the need to quickly find the hidden gun to prevent it from posing a danger justified the officer’s immediate questioning without prior Miranda warnings. The Court emphasized that the social cost of potentially not finding the weapon and the consequent risk to public safety outweighed the procedural safeguard of Miranda warnings in this specific context. Thus, the Court established that in situations presenting a threat to public safety, the need for immediate action can override the requirement for Miranda warnings, allowing evidence obtained in such circumstances to be admissible.
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Oregon v Elstad
Facts
Michael James Elstad was convicted of burglary by an Oregon trial court. The conviction stemmed from a situation where law enforcement officers, having a warrant for Elstad’s arrest, visited his home. Without administering Miranda warnings, one officer initiated a brief conversation in the living room, during which Elstad admitted involvement in a burglary. Later, at the sheriff’s office and after being advised of his Miranda rights, Elstad provided a full written confession. The trial judge admitted the written confession into evidence, despite the earlier unwarned admission being suppressed due to the lack of Miranda warnings. The Oregon Court of Appeals reversed the conviction, suggesting the signed confession was tainted by the initial unwarned admission.
Issue
Does an initial failure to administer Miranda warnings “taint” subsequent admissions made after a suspect has been fully advised of and has waived his Miranda rights?
Holding
The Supreme Court reversed the Oregon Court of Appeals, holding that a suspect’s informed and voluntary confession given after receiving Miranda warnings is not automatically rendered inadmissible due to a prior unwarned, voluntary admission.
Reasoning
The Court reasoned that Miranda warnings aim to protect against violations of the Fifth Amendment’s protection against compelled self-incrimination by creating a procedural safeguard, not a substantive right. An initial failure to administer Miranda warnings, without more (e.g., without coercion or compulsion), does not necessarily “taint” later statements made after the suspect is fully advised of their rights. The Court distinguished between actual coercion and the procedural safeguard provided by Miranda, emphasizing that the latter’s violation does not always bear the same consequence as a direct violation of the Fifth Amendment itself. The Court concluded that a careful and thorough administration of Miranda warnings prior to a subsequent statement can effectively dispel the presumption of compulsion and render the later confession admissible, provided it is voluntary and informed. The Court also noted that understanding the full consequences of one’s decisions is not a prerequisite for a voluntary waiver of rights.
what is a two-step interrogation
- jintial interrogstion
gather information
access credibility
identify potential suspects - Follow-up interrogation
confront suspect with evidence
obtain confession or admission
calrfy inconsistencies
