Code of Criminal Procedure · U.S. Supreme Court, 1981

Edwards v. Arizona

Edwards v. Arizona is a 1981 U.S. Supreme Court decision. This page summarizes key points and works through practice questions for Texas peace officer exam preparation.

Key points

  • Custodial suspect
  • Unambiguous invocation of right to counsel
  • All interrogation must cease
  • Police may not reinitiate interrogation without counsel present (Edwards; Minnick v. Mississippi); the bar covers any offense (Arizona v. Roberson)
  • Exception: suspect-initiated communication, or 14-day break in custody (Shatzer)

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Worked examples

Worked example 1

Once a suspect in custody invokes his right to counsel, officers must:

  1. Continue questioning if a different officer asks
  2. Cease all interrogation and may not reinitiate questioning without counsel present, unless the suspect himself initiates further communication Correct
  3. Wait 24 hours and try again
  4. Get the prosecutor's permission
Why: Edwards: once a custodial suspect clearly invokes the right to counsel, interrogation must cease and police may not reinitiate it unless the suspect himself initiates further communication. Later cases: police may not reinitiate without counsel actually present (Minnick v. Mississippi, 1990); the bar applies to questioning about any offense (Arizona v. Roberson, 1988); a 14-day break in custody ends it (Maryland v. Shatzer).
Statute: Edwards v. Arizona, 451 U.S. 477 (1981)