Montejo v. Louisiana Case Brief

Facts of the case

In March 2005, Jesse Montejo was convicted and sentenced to death for the murder of Lewis Ferrari. At his trial, the prosecution submitted as evidence a letter of apology he wrote to the victim’s wife. Montejo wrote the letter at the suggestion of a detective who accompanied him in a search for the murder weapon. Before the search, Mr. Montejo was read his Miranda rights and wrote an explanation for his participation in the search. However, no one in the search party knew, including Mr. Montejo, that he had been appointed an attorney the same morning. Mr. Montejo contended under these circumstances that the Sixth Amendment barred the introduction of this evidence since his attorney was not present when he wrote and submitted the letter of apology.The Supreme Court of Louisiana held that the letter of apology Mr. Montejo wrote was valid evidence. It found that Mr. Montejo waived his Sixth Amendment right to counsel. It explained that when counsel was appointed Mr. Montejo remained mute and did not acknowledge it. The court reasoned that something beyond mute acquiescenceis required to trigger the protections of the Sixth Amendment.

CONCLUSION

The Supreme Court of the United States held that the rule adopted by the Supreme Court of Louisiana (that a criminal defendant must request counsel, or otherwise assert his Sixth Amendment right at a preliminary hearing, before the Jackson protections were triggered) led either to an unworkable standard, or to arbitrary and anomalous distinctions between defendants in different states. The distinction between those who asserted their right to counsel and those who did not would have been exceedingly hazy when applied to states that appointed counsel absent a request. It would have been completely unjustified to presume that a defendant’s consent to police-initiated interrogation was involuntary or coerced simply because he had previously been appointed a lawyer. The Court held that the marginal benefits of Jackson (the number of confessions obtained coercively that were suppressed by its bright-line rule and would otherwise have been admitted) were dwarfed by its substantial costs (hindering society’s compelling interest in finding, convicting, and punishing those who violate the law). The Court vacated the lower court’s decision and remanded the matter so Montejo could have the opportunity to contend his letter should have been suppressed under Edwards .

  • Advocates: Donald B. Verrilli, Jr. argued the cause for the petitioner Kathryn W. Landry argued the cause for the respondent
  • Petitioner: Jesse Jay Montejo
  • Respondent: State of Louisiana
  • DECIDED BY:Roberts Court
  • Location: Private Residence in St. Tammany Parish
Citation: 556 US 778 (2009)
Argued: Jan 13, 2009
Decided: May 26, 2009
Montejo v. Louisiana Case Brief