Duckworth v. Eagan Case Brief

Facts of the Case

“Respondent, when first questioned by Indiana police in connection with a stabbing, made an exculpatory statement after being read and signing a waiver form that provided, inter alia, that if he could not afford a lawyer, one would be appointed for him “if and when you go to court.” However, 29 hours later, he was interviewed again, signed a different waiver form, confessed to the stabbing, and led officers to a site where they recovered relevant physical evidence. Over respondent’s objection, his two statements were admitted into evidence at trial. After the Indiana Supreme Court upheld his conviction for attempted murder, respondent sought a writ of habeas corpus in the federal district court claiming, among other things, that his confession was inadmissible because the first waiver form did not comply with the requirements of, 384 U.S. 436. The district court denied the petition, holding that the record clearly manifested adherence to. The Court of Appeals for the Seventh Circuit reversed on the ground that the advice that counsel will be appointed “if and when you go to court” was constitutionally defective because it denied the indigent accused a clear and unequivocal warning of the right to appointed counsel before interrogation and linked that right to a future event. The United States Supreme Court granted certiorari review.”




“In a closely divided decision, the Court held that informing Eagan that an attorney would be appointed for him “if and when you go to court” did not render the Miranda warnings inadequate. The Court reasoned that officers did not have to use the specific language of the Miranda decision so long as they reasonably conveyed to suspects their constitutional rights. Chief Justice Rehnquist argued that the instructions given to Eagan accurately described the procedure for the appointment of counsel in Indiana.”

Case Information

Citation: 492 US 195 (1989)
Argued: Mar 29, 1989
Decided: Jun 26, 1989
Case Brief: 1989