Montejo v. Louisiana

While investigating the murder of Lewis Ferrari, police wanted to question Jesse Montejo (defendant). Police arrested Montejo, and Montejo waived his rights under Miranda v. Arizona, 384 U.S. 436 (1966). Montejo was interrogated by police for several hours at the sheriff’s office; he changed his story many times and finally admitted that he had killed Ferrari. Montejo was brought before a judge, and a lawyer was appointed for him even though he had not expressly asked for one. That same day, two detectives visited Montejo and requested that he accompany them to find the murder weapon. He was read his Miranda rights again, and he agreed to go with the officers. During the trip, he wrote an inculpatory apology letter to Ferrari's widow. On returning to prison, Montejo met with his court-appointed lawyer. At trial, Montejo's apology letter was admitted into evidence over the defense’s objection. Montejo was convicted of first-degree murder and sentenced to death. The Louisiana Supreme Court affirmed the conviction. The court held that rule articulated in Michigan v. Jackson, 475 U.S. 625 (1986), which forbids police to initiate an interrogation of a criminal defendant after the defendant has requested counsel at an arraignment or other similar proceeding, was inapplicable because Montejo never expressly asked for an attorney. The court further held that Montejo’s waiver of his right to have counsel present with him during his interactions with the police was knowing and voluntary. The United States Supreme Court granted certiorari.