North Carolina v. Butler
United States Supreme Court
441 U.S. 369 (1979)
Relevant factsFree
After receiving and confirming he understood his Miranda warnings, Butler (defendant) refused to sign a form expressly waiving his rights but agreed to talk with agents anyway, making self-incriminating statements without ever requesting an attorney or trying to stop the questioning. The trial court found his conduct constituted an effective waiver and admitted the statements, but the state supreme court reversed, holding no waiver occurred absent an express statement of intent to waive, and the state sought Supreme Court review.
IssueFree
Whether a suspect may implicitly waive his right to counsel during a custodial interrogation through conduct, without making an express waiver statement.