Minnick v. Mississippi
Minnick v. Mississippi is a significant legal case that centers on the constitutional right against self-incrimination and the right to counsel during custodial interrogations. The case arose when Robert S. Minnick was convicted of murder, and he argued that his confession was obtained in violation of his Fifth Amendment rights. After his arrest, Minnick requested the presence of counsel during questioning, which led to a break in the interrogation. He subsequently consulted with an attorney before being questioned again by a Mississippi deputy sheriff, where he ultimately confessed.
The legal dispute focused on whether Minnick's rights were adequately protected under the precedent set by Edwards v. Arizona, which stipulates that once a suspect has requested counsel, further interrogation should not occur without the attorney present. The Mississippi Supreme Court upheld Minnick's confession, while the U.S. Supreme Court later reversed this decision, ruling that the mere provision of counsel outside the interrogation did not meet the requirement for protection against self-incrimination. This ruling emphasized the importance of having legal representation physically present during any resumption of questioning, impacting law enforcement practices regarding interrogation protocols.
Minnick v. Mississippi
The Case: U.S. Supreme Court ruling on the right to counsel
Date: Decided on December 3, 1990
Significance: This Supreme Court decision found that a reinitiated interrogation of a murder suspect who had been advised of his Miranda rights and received counsel still violated the suspect’s Fifth Amendment rights because it was conducted without counsel being present.
Robert S. Minnick, the petitioner, sought reversal of his conviction for murder in the circuit court of Lowndes County, Mississippi, on the grounds that his constitutional rights against self-incrimination had been violated when his confession was taken during an interrogation conducted without counsel present. Minnick, a fugitive from prison, had been arrested and held in a California jail, where two federal agents, after reading the Miranda warnings to him, began an interrogation on a Friday. He requested that they return on the following Monday, when he would have counsel present. The agents complied, breaking off their questioning. An appointed attorney then advised Minnick to speak to no one about the charges against him. After an interview with the agents on Monday, Minnick was questioned by a deputy sheriff from Mississippi. The deputy advised Minnick of his Miranda rights, and the accused, who refused to sign a waiver of those rights, confessed to the murder for which he was subsequently tried and sentenced to death.
At Minnick’s murder trial in Mississippi, he filed a motion to suppress the confession, but his request was denied. The conviction was then upheld by the Supreme Court of Mississippi, which ruled that Minnick’s right to counsel, as set forth in the Fifth Amendment, had been granted in accordance with the guidelines established in Edwards v. Arizona (1981), which stipulates that a defendant who requests counsel during questioning cannot be subjected to further interrogation until the counsel is “made available” to the defendant. According to the Mississippi Supreme Court, that condition had been met when Minnick consulted with his appointed attorney.
The U.S. Supreme Court, on certiorari, reversed and remanded in a 6-2 decision. In the majority opinion, written by Justice Anthony Kennedy, the justices ruled that in a custodial interrogation, once counsel is provided, questioning cannot be resumed without counsel being present. It stipulated that the Edwards v. Arizona ruling regarding protection against self-incrimination is not met, nor is that protection terminated or suspended, by the mere provision of counsel outside the interrogation process. The majority found that Minnick’s confession to the Mississippi deputy sheriff should have been inadmissible at his murder trial. In a dissenting opinion, Justice Antonin Scalia argued the contrary, holding that the Edwards v. Arizona rule excluding self-incrimination without counsel was not applicable after Minnick’s first interview with his appointed attorney.
The Court’s relatively narrow interpretation of what constitutes right to counsel leaves a legacy of stringent procedural requirements on law-enforcement agencies, which must comply with a suspect’s right to have counsel present during custodial interrogations that had been broken off and later resumed. From the point of view of such agencies, its practical effect is to inhibit an expeditious interrogation of suspects.
Bibliography
Dressler, Joshua. Understanding Criminal Procedure. 3d ed. New York: LexisNexis, 2002.
Taylor, John B. Right to Counsel and Privilege Against Self-Incrimination: Rights and Liberties Under the Law. Santa Barbara, Calif.: ABC-Clio, 2004.
Tomkovicz, James J. The Right to the Assistance of Counsel: A Reference Guide to the United States Constitution. Westport, Conn.: Greenwood Press, 2002.