Crooker v. California

Crooker v. California
Supreme Court of the United States
Argued April 2, 1958
Decided June 30, 1958
Full case nameCrooker v. California
Docket no.178
Citations357 U.S. 433 (more)
78 S. Ct. 1287, 2 L. Ed. 2d 1448, 1958 U.S. LEXIS 665
ArgumentOral argument
Case history
Priorconviction; affirmed 47 Cal. 2d 348, 303 P.2d 753 (1956), cert. granted 354 U.S. 908 (1957)
Holding
A criminal suspect's confession during pre-trial interrogation may be used as evidence, notwithstanding that he was refused the right to an attorney, when the suspect is well-educated, and when it is not proven that the trial was rendered fundamentally unjust and unfair.
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · Felix Frankfurter
William O. Douglas · Harold H. Burton
Tom C. Clark · John M. Harlan II
William J. Brennan Jr. · Charles E. Whittaker
Case opinions
MajorityClark, joined by Frankfurter, Burton, Harlan, Whittaker
DissentDouglas, joined by Warren, Black, Brennan
Laws applied
U.S. Const. amends. V, VI

Crooker v. California, 357 U.S. 433 (1958),[1] was a decision by the Supreme Court of the United States that limited criminal suspects' constitutional right to counsel before trial, refusing to overturn a subsequent conviction without a showing that the refusal of counsel had a coercive or prejudicial effect.[2][3] This holding was later overturned by Escobedo v. Illinois and Miranda v. Arizona.[4][5]

  1. ^ Crooker v. California, 357 U.S. 433 (1959)
  2. ^ Carson, Lyle R. (1959). "Constitutional Law - Rules of Evidence - Effect of Refusal for Request for Counsel on Admissibility of Evidence". North Dakota Law Review. 35: 162–163.
  3. ^ Cappucio, Michael (1965). "Right to Assistance of Counsel During Police Interrogation". University of Miami Law Review. 20: 197–204.
  4. ^ Chang, Helen Y. (2010). "Justice Carter's Dissent in People v. Crooker: An Early Step Towards Miranda Warnings and the Expansion of the Fifth Amendment to Pre-Trial Confessions". In Oppenheimer, David; Brotsky, Allan (eds.). The Great Dissents of the "Lone Dissenter" Justice Jesse W. Carter's Twenty Tumultuous Years on the California Supreme Court. Carolina Academic Press. pp. 25–35. ISBN 978-1-59460-810-0.
  5. ^ Miranda v. Arizona, 384 U.S. 436 (1966)