After being arrested at the scene of a burglary and given Miranda warnings, the defendant said he “wanted a lawyer before answering any questions.” Three days later, while still in custody, and without a lawyer having been appointed, a different officer approached the defendant about an unrelated crime. This officer was unaware of the defendant’s previous request for an attorney. He provided the defendant with Miranda warnings, which the defendant waived. The defendant gave an incriminating statement about the crime for which he had not yet been arrested.
Whether the Edwards rule bars custodial interrogation by another law enforcement officer on other offenses after a defendant has invoked his right to counsel under Miranda?
Yes. A request for counsel under the Fifth Amendment prohibits the government from approaching the defendant about any crime, unless counsel is present.
The principle of Edwards v. Arizona was designed to provide a bright-line rule for law enforcement officers that bars further government-initiated custodial interrogation of a suspect who has requested counsel. It is immaterial whether it is a different law enforcement officer or that the questions are about a different offense. Subsequent law enforcement officer-initiated interrogation will result only in an invalid waiver. Such interrogation may occur only in the presence of counsel or if initiated by the defendant.
486 U.S. 675, 108 S. Ct. 2093 (1988)