Saturday, November 2, 2013

Edwards v. Arizona case brief

Edwards v. Arizona case brief summary
451 U.S. 477 (1981)

Petitioner was convicted of robbery, burglary, and first degree murder. The trial court admitted his post-arrest confession, and the Supreme Court of Arizona affirmed the admission, holding that the confession was valid despite the fact that petitioner had invoked his Fifth Amendment right to counsel during a previous interrogation. The Supreme Court granted petitioner's request for a writ of certiorari.

After he was arrested and read his Miranda rights, petitioner requested an attorney. The police officers ceased questioning, but detectives from the same police department returned the next day and again interrogated petitioner. Petitioner confessed to the crimes during the second interrogation.

The lower courts held that although petitioner had invoked his right to remain silent and his right to counsel, he had waived both rights during the second interrogation after again being informed of his Miranda rights.

  • The Supreme Court held that 
  • (1) the use of petitioner's confession against him violated his Fifth and Fourteenth Amendment rights, where petitioner had asserted his right to counsel and his right to remain silent, and the police, without furnishing him with counsel, returned and secured a confession;
  • (2) petitioner did not validly waive his right to counsel, where there was no finding that he understood his right to counsel and intelligently and knowingly relinquished it; and 
  • (3) having requested counsel, petitioner was not subject to further interrogation until counsel had been made available to him, unless petitioner himself initiated further communication with the police.


The Supreme Court reversed the appellate court's holding that defendant had validly waived his right to counsel.

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

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