Tuesday, April 28, 2009

Arizona v. Roberson, 486 U.S. 675 (1988)

Facts


Roberson was arrested at the scene of a burglary and advised of his Miranda rights.  Roberson replied he wanted a lawyer and this was duly noted.  Three days later, while Roberson was still in custody, a different officer interrogated Roberson about a different burglary.


Procedural History


Roberson moved to suppress his statements and the trial court granted the suppression.


Issue(s)


Did the trial court err in suppressing Roberson’s statements when he previously invoked his right to remain silent and was later interrogated on a different crime?


Holding(s)


No.


Reasoning/Analysis


The Court found that in Edwards, we concluded that reinterrogation may only occur if the accused himself indicates further communication, exchanges, or conversations with the police.  Arizona’s attempt to create an exception to Edwards where there is a separate investigation is unavailing. 


Judgment/Outcome



The Court affirmed the judgment of the Arizona Court of Appeals.

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