Michigan v. Jackson

475 U.S. 625 (1986)

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Nature of the Case

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Facts

During arraignment on second-degree murder charges, Jackson (D) requested that counsel be appointed for him. The police involved were present at the arraignment. Before D had an opportunity to consult with counsel, two police officers obtained another statement from D confirming that D had shot the victim. The questioning was preceded by advice of his Miranda rights and D's agreement to proceed without counsel being present. Such advice had been given six times before. D was convicted and appealed. The Michigan Court of Appeals held that the seventh statement was properly received in evidence. It distinguished Edwards on the ground that Jackson's request for an attorney had been made at his arraignment whereas Edwards' request had been made during a custodial interrogation by the police. Accordingly, it affirmed Jackson's conviction of murder, although it set aside the conspiracy conviction on unrelated grounds. The Michigan Supreme Court held that the post-arraignment statements in both cases should have been suppressed. Noting that the Sixth Amendment right to counsel attached at the time of the arraignments, the court concluded that the Edwards rule 'applies by analogy to those situations where an accused requests counsel before the arraigning magistrate. Once this request occurs, the police may not conduct further interrogations until counsel has been made available to the accused, unless the accused initiates further communications, exchanges, or conversations with the police. . . .