Duckworth v. Eagan – Case Brief Summary (U.S. Supreme Court)

In Duckworth v. Eagan, 492 U.S. 195 (1989), the defendant was brought to police headquarters for questioning regarding the attempted murder of a woman found lying on the beach. (Id. at p. 197.) Before questioning began, officers read the defendant his Miranda rights from a form which provided:

"'before we ask you any questions, you must understand your rights. You have the right to remain silent. Anything you say can be used against you in court. You have a right to talk to a lawyer for advice before we ask you any questions, and to have him with you during questioning. You have this right to the advice and presence of a lawyer even if you cannot afford to hire one. We have no way of giving you a lawyer, but one will be appointed for you, if you wish, if and when you go to court. If you wish to answer questions now without a lawyer present, you have the right to stop answering questions at any time. You also have the right to stop answering at any time until you've talked to a lawyer.' " (Duckworth, at p. 198.)

The defendant signed the form indicating that he understood his rights and was willing to answer questions and make a statement regardless. The defendant provided the police with an "exculpatory explanation for his activities" on the night of the crime. (Ibid.)

Thereafter, the defendant was locked up at police headquarters for approximately 29 hours. (Duckworth, supra, 492 U.S. at p. 198.) Police then initiated another interview, but read the defendant additional Miranda warnings which included a provision that he could stop questioning and request an attorney at any point during the interview. (Duckworth, at p. 199.)

The defendant himself read the form on which the warnings were printed and signed it. The defendant then confessed to stabbing the woman and thereafter, he lead police to the beach where they recovered the knife used in the stabbing and several items of clothing. (Ibid.) Over the defendant's objections the trial court admitted the defendant's confession, his first statement denying involvement, and the knife and clothing. A jury convicted the defendant of attempted murder; the conviction was upheld on appeal. (Id. at pp. 199-200.)

The Seventh Circuit Court of Appeals reversed holding "that his confession was inadmissible because the first waiver form did not comply with Miranda." (Id. at p. 200) The United States Supreme Court granted review "to resolve a conflict among the lower courts as to whether informing a suspect that an attorney would be appointed for him 'if and when you go to court' renders Miranda warnings inadequate." (Id. at pp. 200-201.)

The United States Supreme Court confronted Miranda warnings which included, in addition to the required warnings, the proviso, "We have no way of giving you a lawyer, but one will be appointed for you, if you wish, if and when you go to court." 492 U.S. at 198.

Disagreeing with a majority of the United States Court of Appeals for the Seventh Circuit, who concluded that the suspect "arguably believed that he could not secure a lawyer during interrogation" as a result of this proviso, 492 U.S. at 200, the Supreme Court held that:

"Miranda does not require that attorneys be producible on call, but only that the suspect be informed, as here, that he has the right to an attorney before and during questioning, and that an attorney would be appointed for him if he could not afford one. The Court in Miranda emphasized that it was not suggesting that each police station must have a "station house lawyer" present at all times to advise prisoners. If the police cannot provide appointed counsel, Miranda requires only that the police not question a suspect unless he waives his right to counsel. Here, the suspect did just that." 492 U.S. at 204.

In Duckworth v. Eagan (1989) 492 U.S. 195, 204 109 S. Ct. 2875, 2881, 106 L. Ed. 2d 166, the Supreme Court held, "Miranda does not require that attorneys be producible on call, but only that the suspect be informed, as here, that he has the right to an attorney before and during questioning . . . ." (accord, People v. Nitschmann (1995) 35 Cal. App. 4th 677, 682 41 Cal. Rptr. 2d 325.)

Further, in Duckworth, the court held: "Reviewing courts . . . need not examine Miranda warnings as if construing a will or defining the terms of an easement.

The inquiry is simply whether the warnings reasonably 'convey to a suspect his rights as required by Miranda.' (California v. Prysock (1981) 453 U.S. 355.)" (Duckworth v. Eagan, supra, 492 U.S. at p. 203.)

In Duckworth, the United States Supreme Court described in the admonitions provided to the defendant in some detail.

At 11:00 a.m. on May 17, 1982, the defendant was read the following admonition of rights:

" 'Before we ask you any questions, you must understand your rights. You have the right to remain silent. Anything you say can be used against you in court. You have a right to talk to a lawyer for advice before we ask you any questions, and to have him with you during questioning. You have this right to the advice and presence of a lawyer even if you cannot afford to hire one. We have no way of giving you a lawyer, but one will be appointed for you, if you wish, if and when you go to court. If you wish to answer questions now without a lawyer present, you have the right to stop answering questions at any time. You also have the right to stop answering at any time until you've talked to a lawyer.'" (Duckworth v. Eagan, supra, 492 U.S. at pp. 197-198 109 S. Ct. at pp. 2877-2878.)

The defendant then signed the form and gave an exculpatory statement. (Ibid.)

The United States Supreme Court ruled that it does not. (Duckworth, supra, 492 U.S. at p. 201.) "The prophylactic Miranda warnings are 'not themselves rights protected by the Constitution but are instead measures to insure that the right against compulsory self-incrimination is protected.' Reviewing courts therefore need not examine Miranda warnings as if construing a will or defining the terms of an easement. The inquiry is simply whether the warnings reasonably 'convey to a suspect his rights as required by Miranda.' " (Id. at p. 203)

In sum, the officers read the suspect the following rights: "You have the right to talk to a lawyer for advice before we ask you any questions, and to have him with you during questioning. You have this right to the advice and presence of a lawyer even if you cannot afford to hire one. We have no way of giving you a lawyer, but one will be appointed for you, if you wish, if and when you go to court. If you wish to answer questions now without a lawyer present, you have the right to stop answering questions at any time. You also have the right to stop answering at any time until you've talked to a lawyer." (Id. at p. 198.)

The issue before the Supreme Court was whether the part of the warning that said "counsel would be appointed if and when you go to court" violated Miranda, because it suggested defendant had no right to counsel before the court hearing. The Supreme Court held there was no violation. It reasoned, Miranda mandates only "that the suspect be informed . . . that he has the right to an attorney before and during questioning, and that an attorney would be appointed for him if he could not afford one." ( Id. at p. 204.)

It does not guarantee the right to an immediate attorney or require police stations to have jailhouse attorneys on-call. (Ibid.)

The portion of the warning describing appointment of a lawyer "if and when" the suspect went to court described the procedure for the appointment of counsel; it did not "misinform" the suspect of his right to speak to counsel before the interrogation and to have counsel present at the interrogation, rights which were made clear to him twice during the prophylactic warnings and which he claimed he understood. ( Id. at p. 205.)