Monday, November 4, 2013

Patterson v. Illinois case brief

Patterson v. Illinois case brief summary
487 U.S. 285 (1988)

CASE SYNOPSIS
Petitioner challenged an order from the Supreme Court of Illinois that determined that petitioner had properly waived his U.S. Constitutional Amendment VI right to counsel at a post-indictment interrogation and, thus, was properly convicted of murder after statements made during the interrogation were introduced at his trial.

CASE FACTS
After being indicted for murder, petitioner voluntarily spoke with authorities regarding his role in the crime. Prior to receiving his statements, the authorities read petitioner his Miranda warnings and had petitioner initial each one separately. At trial, the prosecution introduced petitioner's inculpatory statements as evidence, and petitioner was convicted of murder. On appeal, petitioner argued that he had not knowingly and intelligently waived his U.S. Constitutional Amendment VI rights. He contended that the Miranda warnings, which were adequate for protecting his U.S. Constitutional Amendment V rights, were not adequate for protecting his U.S. Constitutional Amendment VI rights.

DISCUSSION
  • The Court disagreed, finding that an accused who was admonished with Miranda warnings had been sufficiently apprised of the nature of his U.S. Constitutional Amendment VI rights, and of the consequences of abandoning those rights, so that his waiver on that basis would be considered a knowing and intelligent one. 
  • The Court stated that it seemed self-evident that one who was told that he had such rights to counsel was in a curious posture to later complain that his waiver of those rights was unknowing.

CONCLUSION

The Court affirmed the order from the state court that determined that petitioner's waiver of his right to counsel at a post-indictment interrogation was proper.

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

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