PATTERSON V. ILLINOIS 487 U.S. 285 (1988) CASE BRIEF

PATTERSON V. ILLINOIS

487 U.S. 285 (1988)

NATURE OF THE CASE: Patterson appealed the denial of a motion to suppress inculpatory statements claiming that Miranda warnings were not sufficient enough to inform him of his Sixth Amendment rights.

FACTS: Jackson was found dead face down in a puddle after being beaten and put there by Patterson (D) and fellow gang members. Police got warrants for battery and mob action but had no idea someone had died. One of the gang members brought them up to speed and D was eventually arrested. D was informed of his rights under Miranda and volunteered to answer questions put to him by the police. D gave a statement concerning the initial fight, but denied knowing anything about the death. A grand jury indicted D and two others for the murder of Jackson. D was removed from the lockup and told that because he had been indicted, he was being transferred to the Cook County jail. When D learned of who had been indicted, he stated, 'Why wasn't he indicted, he did everything.' D also began to explain that there was a witness who would support his account of the crime. The officer interrupted D, and handed him a Miranda waiver form. The officer read the warnings aloud, as D read along with him. D initialed each of the five warnings, and signed the waiver form. D then gave a lengthy statement to police officers concerning the Jackson murder. Later that day, D confessed involvement in the murder for a second time. This confession came in an interview with the Assistant State's Attorney. At the outset the attorney reviewed the Miranda waiver D had previously signed, and D confirmed that he had signed the waiver and understood his rights. D then gave another inculpatory statement concerning the crime. D moved to suppress his statements, arguing that they were obtained in a manner at odds with various constitutional guarantees. The trial court denied these motions. D was convicted. On appeal, D claimed that he had not 'knowingly and intelligently' waived his Sixth Amendment right to counsel. While the Miranda warning was adequate for the purposes of protecting his Fifth Amendment rights it did not adequately inform him of his Sixth Amendment right to counsel. The Illinois Supreme Court disagreed. The Supreme Court granted certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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