Crooker v. California (1957)
- Docket
- 178
- Decided
- 1957-01-01
Summary
Question: Is a confession obtained during an interrogation in which the suspect asked for and was denied access to counsel obtained in violation of the suspect’s Fourteenth Amendment right to due process? Conclusion: No. Justice Tom C. Clark delivered the opinion for the 5-4 majority. The Court held that the coercion that might occur from a denial of a specific request for counsel can be negated by factors such as the defendant’s age, intelligence, and education. In this case, Crooker had knowledge of his rights based on the fact that he was a law student and that he refused to answer some questions during interrogation. Additionally, Crooker was informed by the police officer that he didn’t have to answer anything he didn’t want to. Therefore, Crooker’s confession was not coerced. The Court also held that, although Crooker’s confession was made without counsel being present, his awareness of his rights meant that the absence of counsel did not violate the Due Process Clause of the Fourteenth Amendment. Justice Douglas wrote a dissenting opinion in which he argued that the repeated denial of counsel to Crooker was a violation of his Due Process right. Justice Black also argued that the preservation of Due Process should also be applied to pre-trial investigation and therefore that the accused who wants counsel should have one at any time after the arrest. Chief Justice Earl Warren, Justice Black Hugo L. Black, and Justice William J. Brennan, Jr. joined in the dissent.