Facts
Butler and Lee had robbed a gas station and shot the attendant. The FBI arrested Butler, and after determining he had an 11th grade education and was literate, gave him the Bureau’s Advice of Rights form. Butler stated he understood the rights but refused to sign the waiver on the form. Butler then made inculpatory statements.
Procedural History
Butler moved to suppress his statements and the court denied the motion. The North Carolina Supreme Court reversed, finding that waiver of the right to counsel must be specifically made after the Miranda warnings are given.
Issue(s)
Did the North Carolina Supreme Court err in finding that no statement shall be admitted unless the accused explicitly waived the right to an attorney?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that an express oral or written statement is strong proof of the waiver, but is not inevitably necessary or sufficient to establish waiver. The question of waiver must be determined on the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused.
Judgment/Outcome
The Court vacated and remanded the judgment of the North Carolina Supreme Court.
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