Massiah v. United States
Massiah v. United States is a significant Supreme Court case that addressed the rights of defendants under the Sixth Amendment, specifically the right to counsel. The case arose when Winston Massiah was indicted for drug trafficking and subsequently made incriminating statements to a co-defendant who was secretly working as a government informant. These statements were later used as evidence against him in court, despite the fact that he had retained legal counsel after his indictment. The Supreme Court ruled by a 6-3 decision, stating that the introduction of these statements violated Massiah's right to counsel, as adversarial proceedings had already begun. Justice Potter Stewart, writing for the majority, emphasized that any evidence obtained from a defendant without the presence of their lawyer is inadmissible unless the defendant has waived this right. This ruling set a precedent for the protection of defendants' rights, reinforcing the principle that the right to counsel is paramount once formal charges are filed. The dissenting opinion highlighted concerns about the necessity of the exclusionary rule in cases where police coercion was not evident. Overall, Massiah v. United States established important legal standards regarding the interaction between defendants and law enforcement, marking a pivotal moment in the interpretation of constitutional rights.
Massiah v. United States
Date: May 18, 1964
Citation: 377 U.S. 201
Issues: Right to counsel; exclusionary rule
Significance: In one of a series of cases expanding the rights of criminal defendants, the Supreme Court held that the prosecution may not use evidence deliberately elicited from an indicted defendant when not in the presence of counsel.
After a federal grand jury indicted Winston Massiah and a codefendant on charges of transporting cocaine from South America, Massiah retained a lawyer and was released on bail. He then met with the codefendant who had secretly become a government informant, and Massiah made incriminating statements that were overheard by a federal agent. At the subsequent trial, the judge allowed the agent to testify about the content of the conversation. After Massiah was found guilty in a trial, his lawyers appealed and referred to Spano v. New York (1959), in which the Court had considered the totality of circumstances in holding that the prosecution could not use an involuntary confession elicited from a defendant after his indictment.
By a 6-3 vote, the Supreme Court overturned Massiah’s conviction and ruled that the overheard statements could not be introduced as evidence in a criminal trial. Speaking for the majority, Justice Potter Stewart based the decision almost entirely on the Sixth Amendment right to counsel. Once adversary proceedings begin, the defendant has the right to counsel, and therefore, the prosecution may not use any evidence elicited from the defendant outside the presence of a lawyer unless the defendant waives the right. In a strong dissent, Justice Byron R. White argued that the exclusionary rule was not necessary in this situation because there had been “no inherent danger of police coercion.”
Massiah was the first confession case that explicitly relied on Sixth Amendment analysis. That same year, the Court in Escobedo v. Illinois (1964) held that the right to counsel begins when the suspect becomes the focus of investigation. The Court applied and expanded the prohibition on the elicitation of information from suspects absent counsel in Brewer v. Williams (1977).