Why is the case important?
The petitioner, Robert Minnick (the “petitioner”), escaped from prison with another inmate, and they allegedly killed two people during their escape. The petitioner asked for counsel and was granted counsel. The authorities continued their interrogation afterward, and it led to incriminating evidence.
Facts of the case
“Robert S. Minnick and James Dyess escaped from the Clark County Jail. The next day, they broke into a mobile home to search for weapons. While in the home, the owner returned with a friend and the friend’s infant son. Minnick and Dyess shot and killed the two adults and tied up two young women who arrived later. Minnick and Dyess fled to Mexico, but after a falling out, Minnick went to California alone where police arrested him on a warrant for the Mississippi murders.After the arrest, two FBI officers came to interview Minnick at the San Diego Jail. Minnick refused, asking the officers to “Come back Monday when I have a lawyer.” Minnick did meet with an appointed lawyer on two or three occasions. The next Monday, the deputy sheriff of Clark County came to question Minnick. Prison officials told Minnick he “could not refuse” to speak to the sheriff. The deputy sheriff advised Minnick of his rights and Minnick refused to sign a waiver form. Minnick then confessed to one of the murders, saying that Dyess forced him to shoot. At trial, Minnick moved to suppress those statements, but the court denied the motion, reasoning that Edwards v Arizona only required counsel to be made available to an accused. Minnick argued that he was entitled to have counsel present at all questioning. The jury found Minnick guilty of capital murder and sentenced him to death. The Supreme Court of Mississippi affirmed, holding that Minnick’s Fifth Amendment right to counsel was satisfied because he had met with counsel.”
Whether interrogations can continue after counsel is requested, regardless of whether counsel was consulted or not?
The United States Supreme Court (Supreme Court) held that interrogations can not continue after the suspect requests counsel, whether or not he actually consulted with counsel. The Supreme Court followed the irrebuttable presumption reasoning in Edwards v. Arizona (451 U.S. 477 (1981)), which prohibited the badgering of a detainee until he waives his rights. The court noted that the petitioner did not seem to understand his rights as he refused to sign waivers and requested counsel, but still acquiesced to the interrogations.
“The United States Supreme Court found that that Minnick’s Fifth Amendment protection was not terminated or suspended by consultation with counsel. When counsel is requested, interrogation must cease, and officials may not reinitiate interrogation without counsel present, whether or not the accused has consulted with his attorney. In context, the requirement that counsel be “”made available”” to the accused refers not to the opportunity to consult with an attorney outside the interrogation room, but to the right to have the attorney present during custodial interrogation. This rule is appropriate and necessary, since a single consultation with an attorney does not remove the suspect from persistent attempts by officials to persuade him to waive his rights and from the coercive pressures that accompany custody and may increase as it is prolonged. The proposed exception is inconsistent with Edwards’ purpose to protect a suspect’s right to have counsel present at custodial interrogation and with Miranda v. Arizona , 384 U.S. 436, 16 L. Ed. 2d 694, 86 S. Ct. 1602 , where the theory that the opportunity to consult with one’s attorney would substantially counteract the compulsion created by custodial interrogation was specifically rejected. It also would undermine the advantages flowing from Edwards’ clear and unequivocal character. Since, under respondent’s formulation of the rule, Edwards’ protection could be reinstated by a subsequent request for counsel, it could pass in and out of existence multiple times, a vagary that would spread confusion through the justice system and lead to a loss of respect for the underlying constitutional principle. And such an exception would leave uncertain the sort of consultation required to displace Edwards . In addition, allowing a suspect whose counsel is prompt to lose Edwards’ protection while one whose counsel is dilatory would not would distort the proper conception of an attorney’s duty to his client and set a course at odds with what ought to be effective representation. Since Minnick’s interrogation was initiated by the police in a formal interview that he was compelled to attend, after Minnick had previously made a specific request for counsel, it was impermissible.”
- Case Brief: 1990
- Petitioner: Robert S. Minnick
- Respondent: Mississippi
- Decided by: Rehnquist Court
Citation: 498 US 146 (1990)
Argued: Oct 3, 1990
Decided: Dec 3, 1990
Granted Apr 23, 1990