Tuesday, November 5, 2013

Duckworth v. Eagan case brief

Duckworth v. Eagan case brief summary
492 U.S. 195 (1989)

Respondent prisoner was convicted of attempted murder. The United States Court of Appeals for the Seventh Circuit reversed the denial of his petition for a writ of habeas corpus, finding that he was not properly Mirandized. Petitioner warden sought review, and the Court granted certiorari to resolve a lower court conflict as what would render Miranda warnings inadequate.

The prisoner confessed to stabbing a woman nine times after she refused to have sexual relations with him, and he was convicted of attempted murder. Before confessing, the prisoner was given warnings by the police, which included the advice that a lawyer would be appointed "if and when" the prisoner went to court. In reversing the denial of the prisoner's petition for habeas relief, the court of appeals held that such advice did not comply with the requirements of Miranda.

  • On appeal, the Court held that the initial warnings given to the prisoner touched all of the bases required by Miranda. 
  • The police also added that they could not provide the prisoner with a lawyer, but that one would be appointed if and when he went to court.
  • It would be relatively commonplace for a suspect, after receiving Miranda warnings, to ask when he will obtain counsel. 
  • The "if and when you go to court" advice simply anticipated that question. 
  • Miranda did not require that attorneys be producible on call, but only that the suspect be informed, as here, that he had the right to an attorney before and during questioning, and that an attorney would be appointed for him if he could not afford one.


The court reversed the judgment of the court of appeals and remanded the cause of action for further proceedings.

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

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