Experimental. Doctrines is a new Annlex feature, starting with four areas: Self-incrimination, Brady, Terry and Miranda. Each page collects what courts have said about a leading case, quoted from the opinions that cite it. Annlex Chat uses these collections to help find relevant cases; what a case holds still comes from its opinion. We'd like to hear what's useful, missing or wrong: Send feedback
Edwards bar to reinterrogation applies across separate investigations
Leading case
Arizona v. Roberson, 486 U.S. 675 (1988)
How courts have described it
concluding that Edwards applies when a police-initiated interrogation following a suspect’s request for counsel occurs in the context of a separate investigation
Van Hook v. Anderson (6th Cir. 2007)
holding that police may not question a defendant about any unrelated crimes after invocation of the right to counsel, even if such crimes are the subject of a separate investigation
Robert Van Hook v. Carl S. Anderson, Warden, 444 F.3d 830 (6th Cir. 2006)
holding that the Edwards rule applies even when the suspect’s request for the cessation of questioning occurs in a separate criminal investigation
United States v. Jeffrey Thomas Whaley, Cross-Appellee, 13 F.3d 963 (6th Cir. 1994)
holding that reinterrogation of defendant, who remained in police custody, three days after he requested attorney violated defendant's Miranda right to counsel
Wilson v. State, 274 So. 3d 549 (Fla. Dist. Ct. App. 2019)
concluding that Edwards rule applies to situations in which a suspect invokes Fifth Amendment right to counsel regarding one crime and is then interrogated about another crime
Bilford Junious v. State (Tex. App. 2010)
holding that a defendant who invokes the right to counsel for interrogation on one offense may not be re-approached regarding a separate offense unless counsel is present
Atteberry v. State, 911 N.E.2d 601 (Ind. Ct. App. 2009)
holding that a suspect’s request for counsel indicates an unwillingness to answer without an attorney present any questions police may pose, and this unwillingness is not investigation-specific
State v. Thompson, 987 So. 2d 163 (Fla. Dist. Ct. App. 2008)
Related doctrines
About this page
The quotations above are from court opinions that cite the leading case, in each court's own words. The heading is a short label Annlex generated from those quotations. It has not been reviewed by a lawyer and is not legal advice.