Minnick v. Mississippi
Citation and Court
498 U.S. 146 (1990) — Supreme Court of the United States
Facts
Minnick, arrested in California on a Mississippi murder warrant, invoked his right to counsel during initial interrogation. He was permitted to meet with an appointed attorney over several days. After those meetings, Mississippi officers approached Minnick and, without his attorney present, obtained incriminating statements that were used at trial.
Issue
Whether the Edwards v. Arizona rule — prohibiting police from reinitating interrogation after a suspect invokes the right to counsel — applies even after the suspect has had the opportunity to consult with counsel.
Holding
Yes; once a suspect invokes the right to counsel during a custodial interrogation, police may not re-initiate interrogation without counsel present, even after the suspect has consulted with an attorney in the interim.
Rule / Doctrine
Edwards v. Arizona created a bright-line rule: once an accused requests counsel, interrogation must cease and may not resume unless counsel is present. Minnick extended this rule to prevent the government from arguing that a prior consultation with counsel satisfied the Edwards protection. The protection persists until the suspect reinitiates communication or counsel is present at the subsequent interrogation.
Significance
Strengthened the Edwards prophylactic rule by closing the loophole that would have allowed police to resume interrogation after a one-time consultation, ensuring continuous protection of the invoked right to counsel.