Sunday, November 3, 2013

Massiah v. United States case brief

Massiah v. United States case brief summary
377 U.S. 201 (1964)

The court granted certiorari to the United States Court of Appeals for the Second Circuit to decide whether the prosecution's use at trial of surreptitiously obtained evidence of petitioner's own incriminating statements while he was free on bail deprived him of any right secured under the U.S. Constitution.

The Supreme Court reversed a judgment of a court of appeals, which had affirmed a judgment of conviction against petitioner for violation of federal narcotics laws.

The Supreme Court held that petitioner was denied the basic protections of U.S. Constitutional Amendment VI when there was used against him at his trial evidence of his own incriminating words, which federal agents had deliberately and secretly elicited from him after he had been indicted and in the absence of his counsel.

  • The court found that any secret interrogation of petitioner, from and after the finding of the indictment, without the protection afforded by the presence of counsel, contravened the basic dictates of fairness in the conduct of the criminal cause and the fundamental rights of petitioner. 
  • Petitioner was as much entitled to aid of counsel during the critical period after arraignment and until the beginning of trial as at the trial itself. 
  • Here, petitioner was seriously imposed upon since he did not even know that he was under interrogation by a government agent.


The judgment of a court of appeals affirming petitioner's conviction was reversed as petitioner was as much entitled to aid of counsel after his release on bail as at his trial. Federal agents' indirect procurement of incriminating statements while petitioner was free on bail and without petitioner's knowledge denied petitioner's right to counsel.

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

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