Escobedo v. Illinois facts for kids
Quick facts for kids Escobedo v. Illinois |
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| Argued April 29, 1964 Decided June 22, 1964 |
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| Full case name | Escobedo v. Illinois |
| Citations | 378 U.S. 478 (more)
84 S. Ct. 1758; 12 L. Ed. 2d 977; 1964 U.S. LEXIS 827; 4 Ohio Misc. 197; 32 Ohio Op. 2d 31
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| Prior history | Defendant convicted in Cook County criminal court; Illinois Supreme Court found confession inadmissible and reversed, February 1, 1963; on petition for rehearing, Illinois Supreme Court affirmed conviction, 28 Ill. 2d 41; cert. granted, 375 U.S. 902 |
| Holding | |
| Suspects have the right to a lawyer while being questioned by police. If police refuse to allow a lawyer, anything the suspect says cannot be used in court. | |
| Court membership | |
| Case opinions | |
| Majority | Goldberg, joined by Warren, Black, Douglas, Brennan |
| Dissent | Harlan |
| Dissent | Stewart |
| Dissent | White, joined by Stewart, Clark |
| Laws applied | |
| Sixth and Fourteenth Amendments | |
Escobedo v. Illinois, 378 U.S. 478 (1964), was a very important U.S. Supreme Court case. It was decided in 1964. The Court ruled that people suspected of crimes have the right to have a lawyer with them. This is true even when police are asking them questions.
This decision came just one year after another big case. That case was Gideon v. Wainwright, 372 U.S. 335 (1963). In Gideon, the Court said that poor people accused of crimes had a right to free lawyers for their trial.
Contents
Background of the Case
Police Questioning
The case started with a man named Danny Escobedo. Police were questioning him about a murder. Escobedo asked to speak to his lawyer. But the police said no. They told him he was in their custody and could not leave.
Escobedo's lawyer came to the police station. He asked many times to see Escobedo. But the police would not let him.
Police and prosecutors questioned Escobedo for 15 hours. They made him stand, with handcuffs, the whole time. Escobedo kept asking for his lawyer. The police kept refusing.
Escobedo later said the police promised he could go free. They said he would not be charged with murder. He just needed to say something about the crime. Finally, Escobedo said something that police took as an indirect admission.
Trial and Conviction
At his murder trial, the prosecution used what Escobedo said as key evidence. A jury found Escobedo guilty of murder. He was sentenced to 20 years in prison.
Appeals Process
Escobedo decided to appeal his conviction. He wrote the appeal himself at first. His trial lawyer would not help him. Later, a volunteer lawyer named Barry Kroll helped him.
They argued that Escobedo's right to a lawyer was broken. They also said his admission was made under pressure and false promises.
At first, the Illinois Supreme Court agreed. They decided Escobedo should get a new trial. But then, they changed their minds. They decided he was guilty after all. They refused to change the original sentence.
So, Kroll and Escobedo appealed to the U.S. Supreme Court. The Court agreed to hear their case.
The Supreme Court's Review
Important Legal Questions
The Sixth Amendment to the United States Constitution talks about rights in criminal cases. It says people have the right to a lawyer "for his defence."
The Supreme Court had already said people had the right to a lawyer during trials. But they thought this right started after someone was formally accused.
Now, the Court had to decide new questions:
- Do people have the right to a lawyer during police questioning?
- If police stop a suspect from seeing a lawyer, does that break the Sixth Amendment?
- If so, can anything the suspect says then be used in court? (This is called inadmissible evidence.)
Arguments Presented
For Escobedo
The American Civil Liberties Union (ACLU) helped lawyer Barry Kroll. They argued that police broke Escobedo's Sixth Amendment rights. They also said his Fourteenth Amendment rights were violated.
The Fourteenth Amendment says states cannot take away a person's freedom without "due process of law." Escobedo's team argued that police took away his freedom unfairly by:
- Not letting him have a lawyer. This denied his Sixth Amendment right. It also denied his right to a fair process.
- Not telling him about his rights. For example, his right to remain silent.
Against Escobedo
Lawyers for Illinois argued that the police acted correctly. They said the law and past court cases meant the right to a lawyer only started after a person was charged.
Illinois also argued that a ruling for Escobedo would be bad for law enforcement. If lawyers had to be at every questioning, it would be very hard to get admissions.
The Court's Decision
The Escobedo case caused a big disagreement among the Supreme Court justices. By a vote of 5-4, the Court ruled in favor of Escobedo. They threw out his conviction, and he was set free.
The Court decided that the Sixth Amendment does apply to police questioning. This means people have the right to a lawyer when police question them.
The Court said this right to a lawyer starts even before a person is charged. It begins when police start treating someone like a suspect.
Justice Arthur J. Goldberg wrote the main opinion for the Court. He disagreed with Illinois's argument about lawyers hurting law enforcement. He wrote:
No system of criminal justice can, or should, survive if it depends on citizens not knowing their constitutional rights. No system worth keeping should fear that if an accused talks with a lawyer, he will learn and use these rights. If using constitutional rights harms law enforcement, then something is very wrong with that system.
Why This Case Is Important
The Escobedo decision changed things for police, prosecutors, and courts everywhere:
- Police departments had to change their rules. Now, if a suspect asks for a lawyer, they must get one.
- Prosecutors now check that a suspect had a lawyer when they made an admission. This must happen before using it in court.
- Courts now have different rules for deciding if an admission can be used as evidence. If police stop a suspect from seeing a lawyer, anything the suspect says after that cannot be used as evidence.
Escobedo gave suspects more protection. It allowed them to use their Sixth Amendment right to a lawyer as soon as they become a suspect. This is not just after they are formally charged with a crime.
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