Solem v. Stumes
Annotate this Case
465 U.S. 638 (1984)
U.S. Supreme Court
Solem v. Stumes, 465 U.S. 638 (1984)
Solem v. Stumes
Argued November 28, 1983
Decided February 29, 1984
465 U.S. 638
Respondent, a homicide suspect, when arrested on unrelated charges, made incriminating statements to the police about the homicide after the police had twice renewed interrogation despite respondent's having invoked his right to counsel. Respondent was charged with murder and, after the South Dakota trial court refused to suppress the statements made to the police, was convicted of first-degree manslaughter. The South Dakota Supreme Court affirmed. Respondent then filed a petition for a writ of habeas corpus in Federal District Court, which denied the writ. While respondent's appeal was pending, this Court, in Edwards v. Arizona, 451 U. S. 477, held that once a suspect has invoked the right to counsel, any subsequent conversation must be initiated by him. Applying Edwards to this case, the Court of Appeals found that the police had acted unconstitutionally.
Held: Edwards should not be applied retroactively, and therefore the Court of Appeals erred in evaluating the constitutionality of the police conduct in this case under the standards set out in Edwards. Pp. 465 U. S. 642-651.
(a) The criteria guiding resolution of whether a new constitutional decision should be applied retroactively implicate (1) the purpose to be served by the new standards, (2) the extent law enforcement authorities relied on the old standards, and (3) the effect on the administration of justice of a retroactive application of the new standards. Pp. 465 U. S. 642-643.
(b) Complete retroactive effect is most appropriate where a new constitutional principle is designed to enhance the accuracy of criminal trials. Edwards has little to do with the truthfinding function of the criminal trial. The fact that a suspect has requested a lawyer does not mean that statements he makes in response to subsequent police questioning are likely to be inaccurate. Moreover, in those situations where renewed interrogation raises significant doubt as to the voluntariness and reliability of the statements and, therefore, the accuracy of the outcome at trial, it is likely that suppression could be achieved without reliance on the prophylactic rule adopted in Edwards. Pp. 465 U. S. 643-645.
(c) It would be unreasonable to expect law enforcement authorities to have conducted themselves in accordance with Edwards' bright-line rule prior to its announcement. Edwards did not overrule any prior decision
or transform standard practice, but it did establish a new test for when the waiver of right to counsel would be acceptable once the suspect had invoked that right. It cannot be said that the Edwards decision had been "clearly" or "distinctly" foreshadowed. Pp. 465 U. S. 645-650.
(d) The retroactive application of Edwards would have a disruptive effect on the administration of justice. In a significant number of cases, an inquiry, hampered by problems of lost evidence, faulty memory, and missing witnesses, would be required to assess the substantiality of any Edwards claim. P. 465 U. S. 650.
671 F.2d 1150, reversed and remanded.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and BLACKMUN, REHNQUIST, and O'CONNOR, JJ., joined. POWELL, J., filed an opinion concurring in the judgment, post, p. 465 U. S. 651. STEVENS, J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post, p. 465 U. S. 655.
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