Edwards v Arizona, 451 U.S. 477 (1981)
TYPE OF ACTION: Ruling of the Arizona Supreme Court after an appeal which held that the accused has waived both rights of remaining silent and requiring a legal counsel when he voluntarily made his statement to interrogators. Hence, the court upheld that his confession without his counsel was voluntarily and admissible.
FACTS OF THE CASE:
On January 19, 1976, Edwards was arrested for burglary, robbery and first-degree murder. He was issued an arrest warrant on that same day. He was read his rights and was ready for questioning. He agreed to answer the officers’ questions. He made no incriminating statements. However, when Edwards was told that another suspect has already attested and has implicated him, he waived his statement and invoked his right under the Fifth Amendment. He invoked his right to have a legal counsel. He was sent to prison. The next day, two officers went to see Edwards and he said he did not want to see the officers. The prison guard told him he had to talk to them. The officers once again reminded him of his Miranda rights. Edwards agreed to be interrogated. He voluntarily gave himself away and admitted of his criminal action. He incriminated himself.
Edwards was tried in the Arizona state court. The trial court allowed Edwards’ statement to be admitted at trial, holding that the statement made at the prison was voluntary, and Edwards was convicted. The state supreme court held that Edwards had invoked his right to remain silent and his right to counsel the first time he was interrogated, but that he had effectively waived both those rights when the police came to the jail and he voluntarily answered their questions.
CONTENTION OF THE PARTIES:
Arizona: The state court insisted that Edwards have exercised his right on January 19 to have counsel present during interrogation. However, he did not legally waive that right on the 20th.
Edwards: Edwards argued that his confession should be suppressed on the ground that his Miranda rights had been violated when the officers returned to question him after he had invoked his right to counsel.
ISSUES: The voluntariness of the suspect’s confession is the main contention in this case. Can the court deny the petitioner's motion to suppress his confession or statement if it considers such statement to be given by the petitioner voluntarily? Another issue is on the suspect’s knowledge and intelligence in relinquishing his right to counsel. If the court determines the suspect’s full knowledge and intelligence of his confession, can it revoke such claim under the Fifth Amendment?
DECISION: Yes. The Arizona Supreme Court decided based on their conviction that Edwards sufficiently invoked his Miranda rights. It held that Edwards had waived his right to counsel was infirm and so, the court reversed its judgment.
REASONING: The Arizona Court determined and decided that Edwards had waived both rights during the January 20 meeting based on its opinion under the section entitled, “Voluntariness of Waiver,” the Arizona Supreme Court stated that confession in their state are “prima facie involuntary and that the State had the burden of proof in illustrating that the confession was freely and voluntarily made through a preponderance of evidence. The court stated that the issue of voluntariness must be determined according on the totality of the circumstances as it related to whether a suspect’s action was "knowing and intelligent and whether his will [was] overborne". Because Edwards voluntarily gave his statement to the detectives and he gave it even after he was reminded that he has the right not to do so and may call his counsel, the court believes that Edwards knowingly and intelligently submitted to the said confession.
RULE OF LAW: It follows that if the accused has made his self incriminating statement or confession, even after he has been reminded of his Miranda rights and his right under the Fifth Amendment, then, he has waived these rights and put himself accountable for his statement/s. This is considered if the procedure of letting the accused to be quite if he wants to and the instant ceasing of the interrogation once the accused asks for a lawyer has been followed.
