Edwards v. Arizona

Facts

On January 19, a sworn complaint filed in Arizona state court charged Edwards with robbery, burglary, and first-degree murder. He was arrested at home that day. At the police station, officers gave him the warnings required by Miranda v. Arizona (advice that he may stay silent and may have a lawyer). He said he understood them and would answer questions. Told that another suspect in custody had implicated him, he denied involvement and gave a taped alibi. He then asked to make a deal. The officer said he wanted a statement but could not negotiate a deal, and gave Edwards a county attorney's phone number. Edwards called, hung up after a few moments, and said he wanted an attorney before making a deal. Questioning stopped, and he was taken to county jail. At 9:15 the next morning, two detectives who were colleagues of the first officer came to the jail. Told they wished to speak with him, Edwards said he did not want to talk to anyone. The guard told him he had to talk and took him to the detectives. They repeated the Miranda warnings. Edwards said he would talk but first wanted to hear the alleged accomplice's taped statement. After listening, he said he would speak so long as it was not tape-recorded, and then implicated himself in the crime.

Issues

1. Did the Arizona courts apply the right standard for deciding whether Edwards waived his right to counsel, which requires a knowing and intelligent waiver and not only a voluntary statement?
2. Can an accused who has invoked his right to counsel during custodial interrogation be found to have waived it by responding to police-initiated interrogation the next day, after being warned again, when counsel was never made available?

Holding

Edwards invoked his right to counsel on January 19. The police, without making counsel available, initiated interrogation on January 20. His resulting statement was not a valid waiver of the right to counsel and was inadmissible, so the Arizona Supreme Court's waiver holding was infirm.