475 U.S. 625 (1986)
Respondent Rudy Bladel was a disgruntled former railroad employee.1 In December 1978 he murdered three Amtrak employees at the Jackson, Michigan station.2 He was arrested on January 1, 1979.3 After being questioned on two occasions, he was released on January 3.4 He was arrested again on March 22, 1979.5
The next morning Bladel was arraigned.6 He requested appointment of counsel because he was indigent.7 The detective in charge of the investigation was present at the arraignment.8 A notice of appointment was mailed to a law firm that did not receive it until March 27.9 On March 26 two police officers interviewed Bladel in the county jail.10 They advised him of his Miranda rights and obtained a confession.11 Bladel had inquired about his representation several times since the arraignment but had not been told that counsel had been appointed.12
Respondent Robert Jackson was one of four participants in a plan to kill a man on July 12, 1979.13 Arrested on July 30 on an unrelated charge, he made six statements to police before his arraignment at 4:30 p.m. on August 1.14 At the arraignment he requested appointment of counsel while officers involved in the murder investigation were present.15 The following morning, before he had consulted counsel, two officers obtained a seventh statement from him after again advising him of his Miranda rights.16
The Michigan Court of Appeals initially affirmed Bladel's conviction but reversed after reconsideration.17 It affirmed Jackson's murder conviction while setting aside the conspiracy count.18 The Michigan Supreme Court consolidated the appeals.19 It held the post-arraignment statements inadmissible and reversed both convictions.20 The United States Supreme Court granted certiorari in 1985.21
Whether the same rule from Edwards v. Arizona applies to a defendant who has been formally charged with a crime and who has requested appointment of counsel at his arraignment?22
Once an accused requests counsel at arraignment, the Edwards bright-line rule prohibits police from initiating further interrogation until counsel is provided, and any subsequent waiver obtained through police-initiated questioning is invalid under the Sixth Amendment.23
Yes. The Court applied the Edwards rule to the Sixth Amendment claims arising from arraignment requests in these consolidated cases.24 Respondent Rudy Bladel murdered three Amtrak employees at the Jackson station in December 1978.25 After his March 23 arraignment where he requested counsel because he was indigent, two officers interviewed him in jail on March 26 and obtained a confession before the appointed law firm received notice, even though Bladel had inquired about representation several times.26
Arrested on an unrelated charge on July 30, respondent Robert Jackson gave six statements before his August 1 arraignment at 4:30 p.m. Officers from the murder investigation were present.27 He requested counsel at the arraignment, yet the following morning two officers obtained a seventh statement after again advising him of his Miranda rights.28 The Michigan Court of Appeals initially affirmed Bladel's conviction but reversed after reconsideration while affirming Jackson's murder conviction and vacating the conspiracy count.29 The Michigan Supreme Court held the post-arraignment statements inadmissible under the Sixth Amendment and reversed both convictions.30
The United States Supreme Court granted certiorari in 1985. The Court determined that the Sixth Amendment right to counsel at post-arraignment interrogations requires at least as much protection as the Fifth Amendment right at custodial interrogations.31 Because the officers were present at the arraignments, the State could not claim ignorance of the requests.32 The Court therefore held that police-initiated interrogation after an arraignment request for counsel renders any resulting waiver invalid, requiring suppression of both statements.33
The Michigan Supreme Court's judgments suppressing the post-arraignment statements and reversing the convictions are affirmed.34
Related opinions on this issue
Chief Justice Burger concurred only in the judgment. He had concurred only in the judgment in Edwards v. Arizona.35 He had warned that the extraordinary protections afforded persons in custody can be carried too far.36
He observed that the urge for bright-line rules leads to an absolutist, mechanical treatment of the subject.37 The Court's approach exemplifies the infirmity of case-by-case rulemaking.38 Although stare decisis required him to follow Edwards in this context, he stated that the subject plainly calls for reexamination.39
Hard cases can make bad law.40
Justice Rehnquist dissented.41 He argued that Edwards created a prophylactic rule tied exclusively to the Fifth Amendment's prohibition on compelled self-incrimination to prevent police from badgering suspects who have invoked Miranda rights.42 He contended that the same rule makes no sense in the Sixth Amendment context because there is no widespread problem of police denying defendants their Sixth Amendment right to counsel.43
Rehnquist further maintained that the Court's limitation of the rule to defendants who explicitly request counsel at arraignment is incoherent. The Sixth Amendment right does not depend on such a request.44 The majority therefore lacks any analytically sound basis for its extension of Edwards.45