Davis v. United States (1994)
Encyclopedia
Davis v. United States, 512 U.S. 452 (1994), was a 1994 United States Supreme Court case that established that the right to counsel
can only be legally asserted by an "unambiguous or unequivocal request for counsel."
, murdered another naval officer when he refused to pay a $30 debt that was incurred by losing a game of pool. The victim was beaten to death with a pool cue. Only personally-owned pool cues could be taken from the pool hall and Davis owned two pool cues. Naval investigators found blood on Davis's pool cue and several people stated that they had heard Davis confess to the murder. Davis was taken into custody by Naval investigator
s and read his rights under Miranda
. Davis confessed during the interrogation and then made an ambiguous request for an attorney by saying, "Maybe I should talk with an attorney." The investigators asked him if he did want one and he said, "No."
does not establish the right.
The reasoning was that the defendant's rights under Edwards were not sufficiently requested under these facts. The request for an attorney must be clear and unambiguous.
Right to counsel
Right to counsel is currently generally regarded as a constituent of the right to a fair trial, allowing for the defendant to be assisted by counsel , and if he cannot afford his own lawyer, requiring that the government should appoint one for him/her, or pay his/her legal expenses...
can only be legally asserted by an "unambiguous or unequivocal request for counsel."
Factual background
Davis, a member of the United States NavyUnited States Navy
The United States Navy is the naval warfare service branch of the United States Armed Forces and one of the seven uniformed services of the United States. The U.S. Navy is the largest in the world; its battle fleet tonnage is greater than that of the next 13 largest navies combined. The U.S...
, murdered another naval officer when he refused to pay a $30 debt that was incurred by losing a game of pool. The victim was beaten to death with a pool cue. Only personally-owned pool cues could be taken from the pool hall and Davis owned two pool cues. Naval investigators found blood on Davis's pool cue and several people stated that they had heard Davis confess to the murder. Davis was taken into custody by Naval investigator
Naval Criminal Investigative Service
The United States Naval Criminal Investigative Service is the primary security, counter-intelligence, counter-terrorism, and law enforcement agency of the United States Department of the Navy...
s and read his rights under Miranda
Miranda warning
The Miranda warning is a warning given by police in the United States to criminal suspects in police custody before they are interrogated to preserve the admissibility of their statements against them in criminal proceedings. In Miranda v...
. Davis confessed during the interrogation and then made an ambiguous request for an attorney by saying, "Maybe I should talk with an attorney." The investigators asked him if he did want one and he said, "No."
Ruling
The Supreme Court ruled that an ambiguous and unclear request for an attorneyLawyer
A lawyer, according to Black's Law Dictionary, is "a person learned in the law; as an attorney, counsel or solicitor; a person who is practicing law." Law is the system of rules of conduct established by the sovereign government of a society to correct wrongs, maintain the stability of political...
does not establish the right.
The reasoning was that the defendant's rights under Edwards were not sufficiently requested under these facts. The request for an attorney must be clear and unambiguous.