People v. Sanchez, 15 N.Y.2d 387 (1965)
Once an attorney has contacted the police on behalf of a suspect in custody, any subsequent statements made by the suspect during interrogation in the absence of counsel are inadmissible, regardless of whether the suspect was formally considered an “accused,” “suspect,” or “witness.”
Summary
Sanchez was convicted of first-degree murder, and the central issue was the admissibility of his statements to law enforcement. Prior to the interrogation, Sanchez’s attorney contacted the police, requesting to see and speak with his client. The police subsequently interrogated Sanchez without his counsel present, leading to incriminating statements. The New York Court of Appeals reversed the conviction, holding that the statements should have been excluded because they were obtained after Sanchez’s attorney had contacted the police on his behalf. The court emphasized that the critical factor is the attorney’s contact, not the suspect’s formal status or the voluntariness of the statements. The court ordered a new trial where these statements would be inadmissible.
Facts
Sanchez was in police custody. His attorney, who had been previously retained, contacted the police by phone and in person on July 5, 1963, around 5:00 p.m. The attorney informed the police that he wished to see and speak with Sanchez. Despite the attorney’s communication, the police interrogated Sanchez. During this interrogation, conducted without his attorney present, Sanchez made inculpatory statements to both the police and an assistant district attorney.
Procedural History
Sanchez was convicted of first-degree murder in the trial court and sentenced to death. He appealed his conviction to the New York Court of Appeals, arguing that the statements he made to law enforcement officials should have been excluded from evidence. The Court of Appeals reversed the judgment of conviction and ordered a new trial.
Issue(s)
Whether statements obtained from a suspect in police custody are admissible when the suspect’s attorney has contacted the police requesting to see and speak with the suspect, but the interrogation proceeds without the attorney present?
Holding
No, because once an attorney has contacted the police on behalf of a suspect, any subsequent statements made during interrogation in the absence of counsel are inadmissible.
Court’s Reasoning
The Court relied on its prior decisions in People v. Donovan, People v. Failla, and People v. Gunner. The court emphasized that the key fact is that Sanchez incriminated himself while being interrogated by the police without counsel after his attorney had contacted them on his behalf. The court stated, “The significant or operative fact in such cases is that the defendant confessed or otherwise incriminated himself while being interrogated by the police in the absence of counsel after he had requested the aid of an attorney or one retained to represent him had contacted the police in his behalf.” The court rejected the argument that the attorney’s contact was relevant only to the voluntariness of the statements. The trial court’s error in admitting the statements and refusing to instruct the jury to disregard the statements if they found the police denied the attorney access to the defendant was not harmless. The court found no merit in the other arguments raised by the defendant but reversed and ordered a new trial due to the inadmissible statements.