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Criminal Procedure Keyed to Dressler
Edwards v. Arizona
Citation:
451 U.S. 477, 101 S.Ct. 1880, 68 L.Ed.2d 378.Facts
On January 19th, 1976, the defendant was arrested and charged with murder, robbery, and burglary. At the police station, he was informed of his Miranda rights. He denied involvement and gave a taped statement. He then sought to “make a deal,” but said that he wanted an attorney before making a deal. The officers stopped questioning him and transported him to the jail.
At 9:15am the next morning, on January 20th, two detectives came to the jail and asked to speak with the defendant. When a guard came to get the defendant, the defendant said that he did not want to talk to anyone. The guard told him that he had to talk and then took him to meet with the detectives. The officers identified themselves, stated they wanted to talk to him, and informed him of his Miranda rights. The defendant said that he would make a statement so long as it was not tape-recorded. The detectives informed him that the recording was irrelevant since they could testify in court concerning whatever he said. The defendant replied: “I’ll tell you anything you want to know, but I don’t want it on tape.” He then made incriminating statements.
The defendant filed a motion to suppress his confession, arguing that that his Miranda rights had been violated when the officers returned to question him after he had invoked his right to counsel. The trial court denied it and evidence concerning his confession was admitted at trial. He was found guilty. The Arizona Supreme Court affirmed, finding that the defendant had invoked both his right to remain silent and his right to counsel during the interrogation conducted on the night of January 19th, but that he had waived both rights during the January 20th meeting.
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