Massiah v. United States

Massiah v. United States Case Brief

United States Supreme Court
377 U.S. 201 (1964)

ISSUE: May law enforcement agents use incriminating statements obtained surreptitiously from a D in the absence of D's counsel who has already been indicted in evidence against D?
HOLDING: No.
FACTS:
  • D was a sailor aboard the SS Santa Maria, a ship suspected of carrying narcotics from South America to the US
  • Upon arrival at New York, customs agents searched the ship and found 3.5 lbs. of cocaine which they had reason to believe belonged to D
  • D was arrested, arraigned, and indicted on possession of narcotics and then released on bail = formally charged with a crime
  • Colson, one of D's compatriots, turned to the agents and allowed the agents to install in a listening device in Colson's car
  • D and Colson then had a long conversation in Colson's car, and the incriminating statements were used against D at trial
REASONING:
  • Violated 6th Amdt.: D was denied the basic protections of the 6th Amdt. guarantee of assistance of counsel when his incriminating words were used against him at trial, which agents deliberately elicited after D had been indicted and in the absence of D's counsel
    • Pretrial period is just as crucial as the trial itself for constitutional protections
    • Nothing stops the agents from continuing their investigation post-indictment, but they just can't obtain incriminating statements under these conditions
DISSENT - White: 
  • No way that this case presents and unconstitutional interference with Massiah's right to counsel
  • Insufficient showing that voluntary-involuntary test shouldn't be used here
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