Arizona v. Roberson

On April 16, Roberson (defendant) was arrested at the scene of a burglary. After being read his Miranda rights, Roberson stated that he “wanted a lawyer before answering any questions.” Three days later, while Roberson was still in police custody, a different police officer interrogated Roberson about a separate burglary that had occurred on April 15. Roberson had not yet been granted access to counsel. Roberson was again informed of his Miranda rights before this interrogation, and this police officer was not aware that Roberson had already stated that he wanted a lawyer before he would answer any questions. The police officer obtained an incriminating statement from Roberson about the April 15 burglary during this interrogation. Roberson was eventually convicted of the April 16 burglary. During the trial for the April 15 burglary, however, the trial court suppressed the statement that had been obtained during the second interrogation because Roberson had requested an attorney three days before for the previous investigation but had not yet been given one when the second interrogation occurred. The state (plaintiff) appealed, alleging that the rule prohibiting further interrogation of a suspect in police custody who has requested, but not yet received, legal counsel should not apply to separate investigations. The Arizona Court of Appeals affirmed the suppression order. The Arizona Supreme Court denied a petition for review of that order. The United States Supreme Court granted certiorari to resolve conflicts in this matter among other state court decisions.