Monday, November 4, 2013

McNeil v. Wisconsin case brief

McNeil v. Wisconsin case brief summary
501 U.S. 171 (1991)

CASE SYNOPSIS
The Supreme Court of Wisconsin held that defendant's request for counsel at an initial appearance on charges of armed robbery did not constitute an invocation of defendant's right to counsel during questioning and did not preclude an interrogation on unrelated, uncharged offenses. Defendant petitioned for certiorari.

CASE FACTS
Defendant was arrested pursuant to a warrant charging him with an armed robbery. After his initial appearance for the robbery charge, police questioned defendant multiple times pursuant to their investigation of a murder, attempted murder, and armed burglary. Defendant eventually admitted his involvement with the crimes and signed statements. Thereafter, defendant was convicted and sentenced for second-degree murder, attempted first-degree murder, and armed robbery. On appeal, defendant argued that his courtroom appearance with an attorney for the initial charge constituted an invocation of the Miranda right to counsel. Defendant asserted any subsequent waiver of that right was invalid. The state's highest court rejected defendant's argument.

DISCUSSION
  • After granting certiorari, the Court held that defendant invoked his Sixth Amendment right to counsel at his initial appearance. 
  • The Court determined that the Sixth Amendment right to counsel did not bar the admission of defendant's statements. 
  • The Court found that the assertion of the Sixth Amendment right to counsel did not imply an assertion of the Miranda right to counsel. 
  • Therefore, the judgment was affirmed.

CONCLUSION
The state court's holding that defendant's request for counsel at an initial appearance did not constitute an invocation of his right to counsel was affirmed.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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