Escobedo v. Illinois

Escobedo v. Illinois
Supreme Court of the United States
Argued April 29, 1964 Decided June 22, 1964
Full case name	Escobedo v. Illinois
Citations	378 U.S. 478 (more) 84 S. Ct. 1758; 12 L. Ed. 2d 977; 1964 U.S. LEXIS 827; 4 Ohio Misc. 197; 32 Ohio Op. 2d 31
Prior history	Defendant convicted in Cook County criminal court; Illinois Supreme Court held statement inadmissible and reversed, February 1, 1963; on petition for rehearing, Illinois Supreme Court affirmed conviction, 28 Ill. 2d 41; cert. granted, 375 U.S. 902
Subsequent history	reversed and remanded
Holding
Where a police investigation begins to focus on a particular suspect who has been refused counsel, his statements to police are excluded.
Court membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan, Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Goldberg, joined by Warren, Black, Douglas, Brennan
Dissent	Harlan
Dissent	Stewart
Dissent	White, joined by Stewart, Clark
Laws applied
U.S. Const. amends. VI, XIV

Escobedo v. Illinois, 378 U.S. 478 (1964), was a United States Supreme Court case holding that criminal suspects have a right to counsel during police interrogations under the Sixth Amendment. The case was decided a year after the court held in Gideon v. Wainwright, 372 U.S. 335 (1963) that indigent criminal defendants had a right to be provided counsel at trial.

Background

Danny Escobedo's brother-in-law, Manuel Valtierra, was shot and killed on the night of January 19, 1960. Escobedo was arrested without a warrant early the next morning and interrogated. However, Escobedo made no statement to the police and was released that afternoon. Subsequently, Benedict DiGerlando, who was in custody and considered another suspect, told the police that indeed Escobedo fired the fatal shots because the victim had mistreated Escobedo's sister. On January 30, again, the police arrested Escobedo and his sister, Grace. While transporting them to the police station, the police explained that DiGerlando had implicated Escobedo, and urged him and Grace to confess. Escobedo again declined. Escobedo asked to speak to his attorney, but the police refused, explaining that although he was not formally charged yet, he was in custody and could not leave. His attorney went to the police station and repeatedly asked to see his client, but was repeatedly refused access. Police and prosecutors proceeded to interrogate Escobedo for fourteen and a half hours and repeatedly refused his request to speak with his attorney. While being interrogated, Escobedo made statements indicating his knowledge of the crime. After conviction for murder, Escobedo appealed on the basis of being denied the right to counsel.

The court's decision

Escobedo appealed to the Illinois Supreme Court, which initially held the confession inadmissible and reversed the conviction. Illinois petitioned for rehearing and the court then affirmed the conviction. Escobedo appealed to the U.S. Supreme Court. The ACLU argued before the Court as amicus curiae favoring Escobedo.

Later developments

This holding was later implicitly overruled by Miranda v. Arizona in 1966, and the Supreme Court held that pre-indictment interrogations violate the Fifth Amendment, not the Sixth Amendment. As Escobedo was questioned during a custodial interrogation, the result for the appellant would have been the same.

See also

• List of United States Supreme Court cases, volume 378
• Miranda v. Arizona
• Gideon v. Wainwright
• R. v. Brydges