Crooker v. California, 357 U.S. 433 (1958),[1] was a decision by the Supreme Court of the United States that limited criminal suspects' constitutional right to counsel before trial, refusing to overturn a subsequent conviction without a showing that the refusal of counsel had a coercive or prejudicial effect.

Crooker and McCauley were both in their early 30s, had both been divorced or separated from their former spouses, and apparently they had developed a romantic relationship.

[1] Crooker was interrogated in his home and at a west Los Angeles police station over the course of fourteen hours.

With the exception of a procedural issue with sentencing (which the Court rejected), and an argument that the jury had been given alcohol with dinner (to which the Court replied that they'd had all night to sleep it off before trial resumed the next day), all of these grounds surrounded the circumstances of his written confession, and the constitutionality of its use as evidence to convict him.

[8] First, the Court said, whether a confession was voluntary was a factual question, taking into consideration the circumstances and any force used or inducements offered.

This time, the legal discussion was focused only on whether the confession should have been inadmissible as evidence, either because it had been coerced, or because he'd been denied his right to counsel.

In an opinion written by Justice Clark, the Court first noted that this case was the first time it had faced the question of whether a confession would be inadmissible because a suspect was denied counsel.

[9][6] He argued that adequately protecting the right to counsel required a simpler rule (much like the fruit of the poisonous tree), and he opposed the kind of analysis into circumstances that the majority had done:The Court speaks of the education of this petitioner and his ability to take care of himself.

In an opinion written by Mr. Justice Sutherland the Court said [in Powell v. Alabama], 'Even the intelligent and educated layman has small and sometimes no skill in the science of law .

No matter how well educated, and how well trained in the law an accused may be, he is sorely in need of legal advice once he is arrested for an offense that may exact his life The 1964 case Escobedo v. Illinois involved a man who was arrested as a suspect during a murder investigation and was denied an opportunity to speak with a lawyer during the police interrogation.

[3][10] The Supreme Court overturned his conviction, noting distinctions in Illinois criminal law that he was clearly unaware of, and about which a lawyer could have given him advice.

Among the critical circumstances which distinguish that case from this one are that the petitioner there, but not here, was explicitly advised by the police of his constitutional right to remain silent and not to "say anything" in response to the questions, id.

In any event, to the extent that Cicenia or Crooker may be inconsistent with the principles announced today, they are not to be regarded as controlling.In 1966, the Supreme Court decided Miranda v. Arizona, holding that criminal suspects must be clearly told their constitutional rights, or else their statements during police interrogation would be inadmissible as evidence during their trials.