Moran v. Burbine

475 U.S. 412 (1986).

One-Sentence Takeaway: The failure of police to inform a murder suspect of telephone calls from an attorney, who had been contacted by the suspect’s sister, did not deprive the suspect of information necessary to knowingly and intelligently waive his Miranda rights.

Summary:  Defendant was suspected of a murder.  Unbeknownst to Defendant, his sister had retained an attorney who contacted the police and was assured that they would not question Defendant until the next day.  The officers, however, proceeded with the interrogation and did not inform Defendant about their communications with the attorney or that an attorney had been retained by Defendant’s sister.

Defendant waived his Miranda rights and the Supreme Court of the United States ruled that the written waiver was valid.  The Court reasoned that, “[e]vents occurring outside the presence of the suspect and entirely unknown to him surely can have no bearing on the capacity to comprehend and knowingly relinquish a constitutional right.”  The Court further explained:

No doubt the additional information would have been useful to [Defendant]; perhaps even it might have affected his decision to confess. But we have never read the Constitution to require that the police supply a suspect with a flow of information to help him calibrate his self-interest in deciding whether to speak or stand by his rights. Once it is determined that a suspect’s decision not to rely on his rights was uncoerced, that he at all times knew he could stand mute and request a lawyer, and that he was aware of the State’s intention to use his statements to secure a conviction, the analysis is complete and the waiver is valid as a matter of law

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