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United States v. Stewart & Delegal

United States Court of Appeals for the Sixth Circuit

951 F.2d 351 (1991)

Relevant factsFree

After a bank robbery in Cleveland, Tennessee, Ronnie Lee Stewart and Rodney Fred Delegal (defendants), along with two others, went their separate ways. An informant secretly recorded Stewart implicating himself in the robbery, and Stewart later implicated himself again to a jailhouse informant. Separately, Delegal was arrested in Kentucky on unrelated state stolen-vehicle charges and given Miranda warnings; once an FBI agent learned Delegal was also a suspect in the bank robbery, the agent re-read him Miranda warnings and Delegal confessed to that robbery too. Both men were indicted federally, Delegal moved to suppress his confession, the district court denied the motion, and both were convicted and appealed — Delegal on Sixth Amendment right-to-counsel grounds, and Stewart on the ground that a jailhouse informant improperly elicited his confession.

IssueFree

Whether a suspect's right to counsel under the Sixth Amendment is offense specific, such that it does not extend to police questioning about crimes unrelated to the offense already charged.

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