Duckworth v. Eagan
Citation and Court
492 U.S. 195 (1989) — Supreme Court of the United States
Facts
Indiana police arrested Gary Eagan and gave him a Miranda warning card that told him he had the right to an attorney “if and when you go to court.” Eagan argued this language was misleading because it suggested an attorney would be provided only if and when he appeared in court, not immediately during questioning. He later made incriminating statements and sought to suppress them.
Issue
Does a Miranda warning that tells a suspect he has the right to counsel “if and when you go to court” adequately convey the Miranda rights?
Holding
Yes; the “if and when” language, read together with the full warning card, adequately conveyed the Miranda rights because it accurately reflected Indiana’s appointment procedure and a reasonable suspect would understand he had the right to a lawyer before questioning.
Rule / Doctrine
Miranda warnings need not use any particular form of words; they need only “reasonably convey” to suspects their rights. Warnings that accurately describe how the right to counsel operates in that jurisdiction, even if awkwardly phrased, satisfy Miranda so long as they do not mislead the suspect about the existence of the right.
Significance
Duckworth v. Eagan establishes that Miranda warnings are evaluated for their overall adequacy in conveying rights, not for adherence to any particular script. It is paired with Florida v. Powell for the proposition that states and departments have flexibility in wording Miranda cards as long as the essential rights are reasonably conveyed.