Patterson v. Illinois
United States Supreme Court
487 U.S. 285 (1988)
After being indicted for murder, Patterson (defendant) volunteered information about a co-conspirator to police, was then given and signed a Miranda waiver form, and proceeded to confess to the killing; he later repeated incriminating statements to a prosecutor after confirming he understood his previously signed Miranda rights. Patterson moved to suppress the statements, arguing his Sixth Amendment (not just Fifth Amendment) right to counsel required a different, more searching waiver standard once he had been indicted; the trial court denied suppression, he was convicted, and the state supreme court rejected his argument.
Whether a defendant who has been indicted and given Miranda warnings knowingly and intelligently waives his Sixth Amendment right to counsel by choosing to speak to police and incriminating himself.