Brief Fact Summary. The defendant, Robert Williams (the “defendant”), after being arraigned on charges of abducting a 10-year old girl, was traveling with an officer between Davenport and Des Moines, Iowa. Although the defendant’s lawyers instructed that no questioning should take place outside their presence, the defendant was convinced by the officer to give directions to the body of the girl.
Synopsis of Rule of Law. Once judicial proceedings begin, the Sixth Amendment to the United States Constitution (the “Constitution”) dictates that the suspect has a right to counsel.
It is the likelihood of misidentification which violates a defendant's right to due process.View Full Point of Law
Issue. Whether the officer’s conversation with the defendant constitutes an interrogation that violates the defendant’s right to counsel, and therefore requires the suppression of the evidence?
Held. The evidence should be suppressed because the defendant was denied counsel during an interrogation environment. Once judicial proceedings begin, such as the arraignment, assistance of counsel is required. In this case, the defendant not only did not waive his right to counsel, he affirmatively maintained it through several exchanges between the officers.
Dissent. Chief Justice Warren Burger (“J. Burger”) dissented, arguing that the defendant was reminded of his rights multiple times and chose to waive them when he disclosed the body. Under the majority’s reasoning, a suspect can never waive his rights to counsel.
Justice Byron White’s (“J. White”) dissent argued that the facts of the case indicate that the defendant knew of his rights and knowingly and voluntarily waived them. The officer’s statements do not amount to coercion.
Justice Harry Blackmun (“J. Blackmun”) disagreed with the majority’s version of the facts. J. Blackmun believed that not every comment should be seen as an interrogation, and the circumstances here (a missing girl that may still be found alive) would mandate a heightened need for finding the girl.
Concurrence. Justice Lewis Powell (“J. Powell”) directed his remarks to J. Burger’s dissent, and emphasized that a suspect could still waive his right to counsel, but the evidence here indicated that the defendant did not waive his rights.
Discussion. The definition of interrogation here is very broad compared to a case decided a few years later, Rhode Island v. Innis. The important factors in this case were the timing of the interrogation (after a judicial proceeding), the definition of interrogation, and whether the right to counsel was knowingly and voluntarily waived.