Escobedo v. IL: Why is it important?

Several Supreme Court cases, including Escobedo v. Illinos, are vital to the rights of defendants, particularly as it pertains to their legal representation.

Background & Supreme Court case

In January of 1960, Danny Escobedo was interrogated by police regarding the fatal shooting of his brother-in-law, but was released after he refused to make a statement. About a week later, a friend of Escobedo’s was questioned and revealed that Escobedo had in fact fired the fatal shots. Escobedo was arrested that evening after cops determined they had sufficient evidence linking him to the crime.

When Escobedo asked for an attorney, one arrived, but police did not allow the attorney to speak with him. Escobedo repeatedly asked during interrogation to speak with his attorney but police continued to tell him that the attorney did not wish to speak with him. When the case went to trial, Escobedo’s attorney moved to suppress statements he made during the interrogation. The judge denied the motion.

Escobedo appealed his case and in 1964, it made its way to the Supreme Court, where the majority opinion ruled that a suspect is always entitled to an attorney during interrogation, if that interrogation is more than just a general inquiry and is meant to elicit an incriminating statement.

Importance

The issue at stake in this case is whether defendants have the right to counsel during an interrogation. If someone has not been formally indicted, do they have the right to legal representation? The Supreme Court found that Escobedo had been denied the right to an attorney during a critical time in his case: between his arrest and indictment. When police said they had sufficient evidence to link him to the crime, their interrogation ceased to be a “general inquiry” and thus Escobedo had the right to counsel under the Sixth Amendment.

Justice Arthur Goldberg wrote in the majority opinion that it is important for suspects to have access to legal counsel during an interrogation because it is the likeliest time that they could make an incriminating statement and confess to committing a crime. Goldberg wrote that suspects should be informed of their rights before making any sort of statements.

Goldberg’s majority opinion laid out three specific circumstances that illustrated Escobedo’s denied access to counsel:

1. The investigation had become more than a “general inquiry” (as mentioned before)
2. Escobedo had been taken into custody and interrogated with the intention to elicit a confession
3. Escobedo had been denied access to an attorney and police had not properly informed him of his right to remain silent

The ruling in this case builds upon Gideon v. Wainwright, where the Supreme Court found that defendants must be appointed counsel if they cannot afford legal representation on their own.

Miranda v. Arizona clarified Escobedo when it was handed down a few years later, but Escobedo was nonetheless an important victory for a defendant’s right to legal counsel.