Duckworth v. Eagan

Duckworth v. Eagan, 492 U.S. 195 (1989), was a United States Supreme Court case dealing with police behavior when issuing the Miranda warning. The Court's decision was seen as weakening Miranda's protections.[1]

Duckworth v. Eagan
Supreme Court of the United States
Argued March 29, 1989
Decided June 26, 1989
Full case nameJack R. Duckworth v. Gary James Eagan
Citations492 U.S. 195 (more)
109 S. Ct. 2875; 106 L. Ed. 2d 166
Holding
Improperly informing a suspect that an attorney would be appointed for him "if and when you go to court," and then having him later sign a waiver with the proper Miranda warning before he makes incriminating statements does not render Miranda warnings inadequate.
Court membership
Chief Justice
William Rehnquist
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
Case opinions
MajorityRehnquist, joined by White, O'Connor, Scalia, Kennedy
ConcurrenceO'Connor, joined by Scalia
DissentMarshall, joined by Brennan, Blackmun, Stevens
Laws applied
U.S. Const. amend. V

Background

After being questioned in regards to the stabbing of a woman, Gary Eagan was improperly read his Miranda Rights when police told him that he would be provided a lawyer "if and when you go to court." During the police investigation, Eagan did not make any incriminating statements, and waived his Miranda rights. The next day, Eagan was questioned again by police, and signed a waiver with the correct Miranda language. During the interrogation, Eagan confessed to the stabbing of the woman and revealed physical evidence of the crime committed. Later, Eagan claimed that the difference between the language in the first waiver he signed, and the second waiver he signed, made his confession inadmissible in a court of law.[2]

Opinion of the Court

Chief Justice Rehnquist wrote the opinion for the Court.[3] The Supreme Court held that it was not necessary that the warnings be given in the exact form described in the Miranda decision,[4] provided the warnings as a whole fully informed the suspect of his or her rights.[5]

References
  1. "Library/Abstracts". National Council Justice Referral Service. Retrieved January 1, 2012.
  2. "Duckworth v. Eagan, 492 U.S. 195". Oyez: US Supreme Court Media. Retrieved October 5, 2013.
  3. Duckworth v. Eagan, 492 U.S. 195 (1989).
  4. Miranda v. Arizona, 384 U.S. 436 (1966).
  5. (Chapter 5, page 141 of Criminal Investigation "Suspect's Response: Waiver And Alternatives; #4)

Further reading
  • Swanson; Chamelin; Territo; Taylor (2012). Criminal Investigation (Eleventh ed.). New York: McGraw-Hill. ISBN 9780078111525.


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