Facts
Respondent had been held at the police station and advised of his Miranda rights, but refused to execute a written waiver. Respondent’s sister was seeking an attorney for him at the time, unbeknownst to respondent. An attorney contacted the police department and was informed no further questions would be asked that night. An hour later, respondent was interrogated.
Procedural History
Respondent moved to suppress the statements and the court denied the motion, finding that respondent waived his Miranda privileges. The Court of Appeals reversed, finding that respondent should have been informed his attorney called.
Issue(s)
Did the Court of Appeals err in finding that by not informing respondent that his attorney called, he was deprived of information crucial to his ability to waive his rights knowingly and intelligently?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that events occurring outside of the presence of the suspect and entirely unknown to him surely can have no bearing on the capacity to comprehend and knowingly relinquish a constitutional right. We decline to further extend Miranda to include when police are less than forthright in their dealings with an attorney or if they fail to tell a suspect of a lawyer’s unilateral efforts to contact him.
Judgment/Outcome
The Court reversed and remanded the judgment of the Court of Appeals.
Sunday, May 17, 2009
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