Michigan v. Jackson

Michigan v. Jackson, 475 U.S. 625 (1986), was a case decided by the United States Supreme Court regarding the Sixth Amendment's right to counsel in a police interrogation.

In a decision written by Justice Stevens, the Court held that once an accused individual has claimed a right to counsel at a plea hearing or other court proceeding, a waiver of that right during later police questioning would be invalid unless the accused individual initiated the communication.

[2] Respondent Rudy Bladel had been convicted of murdering three railroad employees at the Amtrak station in Jackson, Michigan, on December 31, 1978.

Although Bladel had inquired about his representation several times since the arraignment, he was not told that a law firm had been appointed to represent him.

On the following morning, before he had an opportunity to consult with counsel, two police officers obtained another statement from Jackson to "confirm" that he was the person who had shot the victim.

As was true of the prearraignment statements, the questioning was preceded by advice of his Miranda rights and Jackson's agreement to proceed without counsel being present.

The U.S. Supreme Court had held previously in Edwards v. Arizona, 451 U.S. 477 (1981), that an accused person in custody who has, expressed his desire to deal with the police only through counsel is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication, exchanges, or conversations with the police.

Noting that the Sixth Amendment right to counsel attached at the time of the arraignments, the Michigan Supreme Court concluded that the Edwards rule, applies by analogy to those situations where an accused requests counsel before the arraigning magistrate.

The Court had held previously that the "Sixth Amendment guarantees the accused, at least after the initiation of formal charges, the right to rely on counsel as a 'medium' between him and the State."

We conclude that the assertion is no less significant, and the need for additional safeguards no less clear, when the request for counsel is made at an arraignment and when the basis for the claim is the Sixth Amendment.

[17]The holding in Michigan v. Jackson was narrowed later by the Court in McNeil v. Wisconsin,[18] which held that an accused's invocation of his Sixth Amendment right to counsel during a judicial proceeding does not constitute an invocation of the right to counsel derived by Miranda v. Arizona,[19] from the Fifth Amendment's guarantee against compelled self-incrimination.