Patterson v. Illinois

Facts

The defendant and two other gang members were indicted for murder. The defendant asked a police officer another gang member had been omitted from the indictments. He said that the omitted person “did everything.” The defendant also began to explain that there was a witness who would support his account of the crime.

At this point, the officer interrupted the defendant, and handed him a Miranda waiver form. The officer read the warnings aloud as the defendant read along with him. The defendant signed the waiver form and then gave a lengthy statement to police officers, detailing everyone’s involvement, including his own, in the murder.

Later that day, the defendant confessed involvement in the murder for a second time. This confession came in an interview with an Assistant State’s Attorney. At the outset of the interview, the attorney reviewed with the defendant the Miranda waiver he had previously signed, and the defendant confirmed that he had signed the waiver and understood his rights. The attorney read the warnings to the defendant again and had him sign another form. He also told the defendant that he was a lawyer working with the police.

These confessions were admitted at trial and the defendant was convicted. He appealed, arguing that he had not “knowingly and intelligently” waived his Sixth Amendment right to counsel before he gave his uncounseled post-indictment confessions. He contended that the warnings he received did not adequately inform him of his Sixth Amendment right to counsel. The Illinois Supreme Court rejected this theory and affirmed.