Escobedo v. Illinois (1964)
Escobedo v. Illinois (1964): The Right to Counsel During Police Questioning
Police cannot deny a suspect’s request for a lawyer during interrogation.
Background
Daniel Escobedo was arrested in Chicago and taken for questioning. He repeatedly asked for his attorney, who was present at the station trying to reach him. Police refused access. Escobedo eventually made incriminating statements that were used at trial. He argued that denying him counsel violated his constitutional rights.
Questions Presented
- Does refusing a suspect’s request to speak with an attorney during interrogation violate the Sixth Amendment?
- Are statements obtained after such denial admissible?
Majority Opinion — Justice Arthur Goldberg
Holding: When the police investigation has “focused” on a suspect and they request a lawyer, denying that request and continuing interrogation violates the Sixth Amendment.
Goldberg’s opinion recognized that the right to counsel is essential when the government interrogates someone it has already targeted for prosecution. Police strategies that isolate a suspect and cut off legal help are inherently coercive. Statements obtained in that setting cannot be used by prosecutors.
Escobedo laid the foundation for Miranda by reinforcing the importance of counsel during interrogation. Although later refined, its core remains vital — especially in Texas cases where police delay warnings or discourage attorney contact. Defense lawyers examine every custodial interview for indications that officers ignored requests for legal help.
For Texans accused of a crime, one of the most powerful protections is having an attorney stop harmful questioning — a right Escobedo fought to secure.