People v. Majecki, 54 N.Y.2d 713 (1981)
Once a defendant’s right to counsel has indelibly attached, any statement made as the result of police interrogation, even if it follows the defendant’s initial inquiry, is inadmissible unless the statement is truly spontaneous and not the result of inducement, provocation, encouragement, or acquiescence.
Summary
Majecki was arrested on a robbery warrant. Upon arriving at the police barracks, after being repeatedly advised of his Miranda rights, the officer told Majecki the details of the robbery he was charged with. Majecki then stated, “I did it.” The New York Court of Appeals held that this statement was inadmissible because Majecki’s right to counsel had attached upon the issuance of the arrest warrant, and the officer’s detailed recitation of the crime constituted interrogation, negating any claim of spontaneity. The dissent argued that the officer was merely informing Majecki of the charges against him, and Majecki’s statement was a spontaneous admission of guilt.
Facts
Inspector Connelly arrested Majecki on a first-degree robbery warrant. In the police car, Majecki repeatedly asked what he was being charged with, but Connelly deferred answering until they reached the barracks. At the barracks, after re-advising Majecki of his Miranda rights, Connelly detailed the robbery: “You are charged with the robbery of the Gasland gas station…You did the job with a kid by the name of Lawless…” After Connelly described the crime, Majecki stated, “I did it.” Another officer then informed Connelly that Majecki’s attorney had instructed that no statement be taken.
Procedural History
Majecki moved to suppress his admission, arguing a violation of his right to counsel. The trial court denied the motion, finding the statement spontaneous. The Appellate Division affirmed. The New York Court of Appeals reversed, holding the statement inadmissible.
Issue(s)
Whether a defendant’s statement, made after his right to counsel has attached and after the police have provided detailed information about the crime charged, is admissible as a spontaneous statement, or whether it is the product of interrogation and thus inadmissible in the absence of counsel.
Holding
No, because once the right to counsel attaches, any statement made in response to police conduct that is likely to elicit an incriminating response is considered the product of interrogation and is inadmissible unless counsel is present, and the detailed explanation of the charges in this case constituted such conduct.
Court’s Reasoning
The court reasoned that the issuance of the arrest warrant marked the commencement of criminal action, thus indelibly attaching Majecki’s right to counsel under the New York Constitution, citing People v. Samuels, 49 N.Y.2d 218. Once this right attaches, the police cannot engage in conduct likely to evoke a response from the defendant. The court distinguished a truly spontaneous statement from one induced by police action. “[T]he police are not prohibited from merely informing a suspect of the charges against him, but they may not exploit that knowledge to elicit an incriminating response.” Here, the detailed explanation of the crime went beyond simply informing Majecki of the charges; it was conduct the police should have known was reasonably likely to elicit an incriminating response. The court concluded the statement was not spontaneous, but rather the product of custodial interrogation in the absence of counsel, rendering it inadmissible. The dissent argued that informing a defendant of the charges against them is standard procedure, and that Majecki’s statement was a truly spontaneous admission, emphasizing that the officer merely responded to Majecki’s repeated requests for information. The dissent also cited People v. Lynes, 49 N.Y.2d 286, arguing the cases were indistinguishable because, in both cases, the defendant initiated the conversation and the police made a brief response.