Connecting Miranda and Massiah

Question 1

Patterson v. Illinois,

Answer 1

Facts
The case involves the petitioner, a member of the “Vice Lords” street gang, who became involved in a violent altercation with a rival gang, leading to the death of James Jackson. After the incident, police arrested the petitioner and other gang members. Initially, the petitioner was interrogated regarding the fight but denied any knowledge of Jackson’s death. Subsequently, he was informed of his Miranda rights, which he waived, and provided a statement about the murder. This process repeated with an Assistant State’s Attorney, leading to another inculpatory statement. At trial, the petitioner sought to suppress these statements, arguing they were obtained in violation of his Sixth Amendment right to counsel. The trial court denied this motion, and the statements were admitted, resulting in a conviction. The Illinois Supreme Court affirmed, holding that Miranda warnings were sufficient for Sixth Amendment purposes.

Issue
The core issue is whether the petitioner’s post-indictment interrogation without the presence of counsel, following a waiver of Miranda rights, violated his Sixth Amendment right to counsel.

Holding
The Supreme Court held that the petitioner did not violate his Sixth Amendment right to counsel during post-indictment interrogations as he had not sought to exercise this right and had validly waived it by accepting the Miranda warnings and proceeding with the interrogation.

Question 2

McNeil v. Wisconsin

Answer 2

Facts
Paul McNeil was arrested in Nebraska for an armed robbery in West Allis, Wisconsin. After his arrest, Milwaukee County deputy sheriffs attempted to question him after reading him his Miranda rights, but he refused to answer without requesting an attorney. Later, in Wisconsin, after being represented by an attorney for the armed robbery charge, McNeil was approached by Detective Joseph Butts regarding unrelated crimes in Caledonia, Wisconsin. McNeil was read his Miranda rights again and waived them before providing incriminating statements in three separate interviews about the Caledonia crimes. These statements were made before McNeil was formally charged with the Caledonia crimes. His motion to suppress these statements was denied, and he was convicted based on them.

Issue
The issue before the court was whether McNeil’s invocation of his Sixth Amendment right to counsel during a judicial proceeding for the armed robbery charge constituted an invocation of his Miranda right to counsel for the unrelated Caledonia crimes.

Holding
The Supreme Court held that McNeil’s invocation of his Sixth Amendment right to counsel for the armed robbery charge did not constitute an invocation of his Miranda right to counsel for the unrelated Caledonia crimes. Therefore, McNeil’s waiver of his Miranda rights and subsequent incriminating statements regarding the Caledonia crimes were admissible.

Question 3

Montejo v. Louisiana

Answer 3

Facts
Jesse Montejo was arrested for the murder of Lewis Ferrari. After his arrest, he waived his Miranda rights and underwent police interrogation, during which he provided incriminating evidence. At a preliminary hearing, the court appointed a lawyer for Montejo, but he did not explicitly request one. Later, still without his lawyer, Montejo was interrogated again by the police, during which he wrote an inculpatory letter of apology to the victim’s widow. At his trial, this letter was admitted as evidence, leading to his conviction.
Montejo argued that the letter should have been suppressed under Michigan v. Jackson, which forbids police-initiated interrogation once a defendant has requested counsel at an arraignment or similar proceeding.

Issue
The key issue was whether the rule in Michigan v. Jackson should apply, thereby rendering Montejo’s waiver of counsel and subsequent evidence inadmissible, given that he had not explicitly requested counsel but had one appointed by the court.

Holding
The Supreme Court overruled Michigan v. Jackson. It held that the rule from Jackson was not applicable since Montejo did not explicitly invoke his right to counsel, and therefore, the evidence gathered after his waiver of Miranda rights was admissible