Texas v. Cobb Case Brief

Why is the case important?

The Respondent, Raymond Levi Cobb (the “Respondent”), was indicted for a burglary he confessed to. While in police custody for the burglary charge, he confessed to the murder of the two missing persons from the house he robbed.

Facts of the case

In 1994, while under arrest for an unrelated offense, Raymond Levi Cobb confessed to a home burglary. Cobb, however, denied knowledge of the disappearance of a woman and child from the home. In 1995, after counsel was appointed to represent him in the burglary case, Cobb confessed to killing the woman and child to his father, who contacted the police. Cobb, now in custody, waived his rights under Miranda and confessed to the murders. Cobb was then indicted, convicted, and sentenced to death. On appeal to the Texas Court of Criminal Appeals, Cobb argued that his confession should have been suppressed because it was obtained in violation of his Sixth Amendment right to counsel, which he claimed attached when counsel was appointed in the burglary case. In reversing, the court held that once the right to counsel attaches to the offense charged, it also attaches to any other offense that is very closely factually related to the offense charged.

Question

Whether the Respondent’s right to counsel for the charges of burglary extend to the factually related murder charges and therefore render the police confession inadmissible?

Answer

The confession is admissible because the Respondent waived his Miranda rights, and his right to counsel for the burglary charge would not transfer to the murder charge.

Conclusion

The Supreme Court of the United States reversed the decision from the Texas Court of Criminal Appeals. The Court held that, regardless of whether the murder charge was closely related factually to the burglary offense, the right to counsel was offense specific. Since the two offenses required different elements of proof, they were separate offenses, and prosecution was not initiated on the murder offense at the time of the interrogation. Cobb thus had no right to the presence of his previously appointed counsel during the interrogation concerning the murder charge, and the confession resulting from that interrogation was admissible.

  • Case Brief: 2001
  • Petitioner: Texas
  • Respondent: Cobb
  • Decided by: Rehnquist Court

Citation: 532 US 162 (2001)
Argued: Jan 16, 2001
Decided: Apr 2, 2001