Arizona v. Roberson
In Arizona v. Roberson, 486 U.S. 675 (1988), the defendant (Roberson) was arrested at the scene of a burglary on April 16, 1985. After being advised of his Miranda rights, Roberson told the police that he wanted a lawyer present before he answered any questions. Id. at 678.
Questioning then ceased. Id.
Three days later, when Roberson was still in jail, a different police officer interrogated him about a different burglary. Id. That officer, unaware that the defendant had previously invoked his right to counsel, questioned Roberson after the latter had been advised of, and waived, his Miranda rights. Id.
The officer then obtained an incriminating statement from Roberson about a burglary that occurred one day prior to the burglary for which he was arrested initially.
In Roberson, the Court ruled that the Edwards prohibition against reinterrogation applied even if the reinterrogation was unrelated to the crime that was the focus of the original questioning, and even if the officer who conducts the reinterrogation was unaware that the suspect had previously requested counsel. Id. at 680.
The Court emphasized:
To a suspect who has indicated his inability to cope with the pressures of custodial interrogation by requesting counsel, any further interrogation without counsel having been provided will surely exacerbate whatever compulsion to speak the suspect may be feeling. . . . Especially in a case such as this, in which a period of three days elapsed between the unsatisfied request for counsel and the interrogation about a second offense, there is a serious risk that the mere repetition of the Miranda warnings would not overcome the presumption of coercion that is created by prolonged police custody. Id. at 686.