People v. Robles, 27 N.Y.2d 155 (1970)
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A defendant’s voluntary, spontaneous statements made to police are admissible, even if the defendant is represented by counsel, when the attorney is physically present and has had an opportunity to advise the client.
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Summary
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Robles was convicted of first-degree murder. He argued that statements he made to police at the station house were inadmissible because they were obtained by interrogation in the absence of counsel, relying on People v. Arthur. The New York Court of Appeals affirmed the conviction, holding that the statements were admissible because they were voluntary and spontaneous, not the result of interrogation. Robles’ attorney was physically present at the precinct, had conferred with him, and even placed a detective in the room where Robles made the incriminating statements. The court distinguished this situation from cases where police actively prevented or undermined the defendant’s access to counsel.
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Facts
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After being questioned without effect, Robles was taken to a police precinct. He was placed in a detention pen. His attorney arrived and conferred with him privately for 20 minutes in a clerical office. The attorney then asked a detective to “watch” Robles. The detective sat in the office, and another detective provided Robles with food. When Robles refused to eat, the first detective asked, “Rick, did you ever think it would wind up like this?” Robles replied that he thought he would be arrested for killing the two girls, based on what he read in the newspapers. The detective then asked, “Just what really happened?” Robles confessed to the murders. Later that evening, Robles made further incriminating admissions to an officer while his attorney was in the same room, about 18 feet away.
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Procedural History
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Robles was convicted of two counts of first-degree murder in the Supreme Court, New York County, and sentenced to life imprisonment on each count. The Appellate Division, First Department, affirmed the judgment. Robles appealed to the New York Court of Appeals.
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Issue(s)
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Whether statements made by a defendant to police are inadmissible solely because they were made outside the physical presence of his attorney, when the attorney is in the same building and had previously conferred with the client?
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Holding
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No, because the statements were voluntary, spontaneous, and not the product of custodial interrogation, and the attorney was physically present and had the opportunity to advise the client.
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Court’s Reasoning
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The Court of Appeals found that the lower courts’ finding that Robles’ statements were voluntary was supported by the record. The court distinguished People v. Arthur, stating that the rule in Arthur is not applicable unless there is evidence that police intended to victimize a defendant or outwit his attorney. Here, Robles’ initial statement was not the result of an “inquisitorial” process but rather