451 U.S. 477 (1981).

One-Sentence Takeaway: Once an accused has invoked his Fifth Amendment right to counsel under Miranda v. Arizona, he cannot be subjected to further interrogation by the police until counsel has been made available to him, unless the accused himself initiates further communication, exchanges, or conversations with the police.

Summary:  Edwards was arrested for robbery and murder.  After being given his Miranda rights and waiving them, Edwards made an exculpatory statement.  He then indicated he wished to have an attorney to help him make a deal. The questioning stopped at this point. The next day, after a “guard told him that ‘he had’ to talk” to the police, Edwards met with detectives and was again given his Miranda rights. The detectives then played a taped statement of an alleged accomplice who implicated Edwards in the crime.  After listening to the tape, Edwards waived his Miranda rights and made a statement inculpating himself in the crime.

The Supreme Court held that the second day of interrogation violated Edwards’ Fifth Amendment right to counsel identified in Miranda.  The Court ruled that after a suspect invokes his right to counsel during custodial interrogation, he cannot be reinterrogated while in custody unless his attorney is present or he initiates the questioning.  The Edwards Court said that the issue was decided by the language in Miranda that once a suspect invokes his right to counsel, “the interrogation must cease until an attorney is present.”

The Court rejected the state’s argument that Edwards had waived his Miranda rights:

We now hold that when an accused has invoked his right to have counsel present during custodial interrogation, a valid waiver of that right cannot be established by showing only that he responded to further police-initiated custodial interrogation even if he has been advised of his rights. We further hold that an accused, such as Edwards, having expressed his desire to deal with the police only through counsel, is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication, exchanges, or conversations with the police.

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