People v. Meyer, 21 N.Y.2d 311 (1968)

Once a defendant is formally charged and has legal representation assigned, interrogation without notice to counsel regarding the same or related offenses is a violation of the defendant’s right to counsel, rendering any resulting confession inadmissible.

Summary

Meyer was arraigned on a charge of criminally receiving stolen property and assigned counsel. Upon release on his own recognizance, he was immediately arrested by state police, questioned about a related burglary in another county without his attorney present, and confessed. The New York Court of Appeals held that the confession was inadmissible because Meyer was interrogated without notice to his counsel after counsel had been assigned. The court also found reversible error in the trial judge’s failure to submit the issue of voluntariness of the confession to the jury.

Facts

The key facts are as follows:
1. Meyer was arraigned in New York City Criminal Court on a charge of criminally receiving stolen property.
2. Counsel was assigned to represent him.
3. He was released on his own recognizance.
4. Immediately after his release, he was arrested by New York State Police.
5. Without notice to his assigned counsel, police questioned him about a burglary in Suffolk County involving property related to the New York County charge.
6. Meyer confessed to the burglary.

Procedural History

The case originated in a trial court where Meyer’s confession was admitted as evidence, leading to his conviction. Meyer appealed, arguing that the confession was obtained in violation of his right to counsel and that the trial court erred in its instructions regarding the voluntariness of the confession. The New York Court of Appeals reversed the conviction and ordered a new trial.

Issue(s)

1. Whether the interrogation of a defendant, who is represented by counsel on a related charge, without notice to that counsel violates the defendant’s right to counsel, rendering any confession obtained inadmissible?
2. Whether a trial court commits reversible error by failing to submit the question of the voluntariness of a confession to the jury after instructing them only to consider its truth or falsity?

Holding

1. Yes, because once counsel is assigned, interrogation regarding related charges without notice to counsel violates the defendant’s right to counsel.
2. Yes, because the jury must determine the voluntariness of a confession, not just its truthfulness, before considering it as evidence.

Court’s Reasoning

The court reasoned that once a defendant is represented by counsel, any interrogation without notice to that counsel is impermissible. This rule aims to protect the attorney-client relationship and ensure the defendant’s constitutional rights are upheld. Citing People v. Donovan, the court emphasized the importance of an attorney’s presence during interrogation. The court stated that the confession obtained from Meyer should not have been received in evidence due to the violation of his right to counsel.

Further, the court found reversible error in the trial judge’s failure to properly instruct the jury on the voluntariness of the confession. The court referenced People v. Huntley, highlighting that the jury must determine the voluntariness of a confession beyond a reasonable doubt before considering it as evidence of guilt. The judge’s instruction, which focused solely on the truth or falsity of the confession, deprived Meyer of this crucial safeguard.

The court’s decision underscores the prophylactic role of counsel in safeguarding a defendant’s rights during custodial interrogation and the necessity for the jury to assess voluntariness of confessions independently.