Frazier v. Cupp
Encyclopedia
Frazier v. Cupp, 394 U.S. 731 (1969), was a United States Supreme Court
case that affirmed the legality of deceptive interrogation tactics.
During the interrogation, police falsely informed Frazier that Rawls had already confessed and implicated him in the murder. Frazier denied any involvement in the crime, and suggested speaking with an attorney, but police continued to question him. Police elicited a confession, which was used against him at trial.
Frazier was convicted of the murder of Russell Anton Marleau. Jerry Lee Rawls pleaded guilty to the same offense.
on three main points.
The language of the ruling did not specifically state which forms of police deception were acceptable, but the ruling provided a precedent for a confession being voluntary even though deceptive tactics were used.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case that affirmed the legality of deceptive interrogation tactics.
Background of the case
Acting on a tip, police picked up and interrogated Martin E. Frazier, a 20-year-old U.S. Marine, about his possible involvement in the murder of Russell Anton Marleau. Frazier, along with his cousin, Jerry Lee Rawls, was seen at a bar with the victim before the murder.During the interrogation, police falsely informed Frazier that Rawls had already confessed and implicated him in the murder. Frazier denied any involvement in the crime, and suggested speaking with an attorney, but police continued to question him. Police elicited a confession, which was used against him at trial.
Frazier was convicted of the murder of Russell Anton Marleau. Jerry Lee Rawls pleaded guilty to the same offense.
Arguments during appeal
Frazier appealed his conviction to the United States Supreme CourtSupreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
on three main points.
- The defense argued Frazier was denied his Sixth Amendment right to cross-examine the prosecution's witness, Rawls, because Rawls refused to answer questions after the prosecution referenced elements from his prior statements to police.
- The defense claimed, under Escobedo v. IllinoisEscobedo v. IllinoisEscobedo v. Illinois, 378 U.S. 478 , was a United States Supreme Court case holding that criminal suspects have a right to counsel during police interrogations under the Sixth Amendment. The case was decided a year after the court held in Gideon v...
and Miranda v. ArizonaMiranda v. ArizonaMiranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
, Frazier was denied his right to counsel during his interrogation because questioning continued after he suggested speaking with an attorney. The defense also claimed Frazier's confession was involuntary and should have been suppressed. - The defense argued evidence used against Frazier was obtained during an illegal search of a gym bag used jointly by Frazier and Rawls.
The court's decision
The Court dismissed the petitioner's arguments and upheld the lower court's conviction on the following grounds.- The Court stated the trial judge followed necessary protocol by instructing the jury to disregard the references to Rawls' statements. The Court agreed the prosecution did not emphasize Rawls' statements over other evidence, and the statements alone was not "touted to the jury as a crucial part of the prosecution's case.
- The Court ruled Frazier did not formally request an attorney, as required for Escobedo v. IllinoisEscobedo v. IllinoisEscobedo v. Illinois, 378 U.S. 478 , was a United States Supreme Court case holding that criminal suspects have a right to counsel during police interrogations under the Sixth Amendment. The case was decided a year after the court held in Gideon v...
to apply, and Miranda v. ArizonaMiranda v. ArizonaMiranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
did not apply because the original trial took place in 1965, one year before Miranda. The Court also ruled that the misleading statement on its own did not render the confession involuntary, based on a "totality of the circumstances" view. - The Court dismissed the illegal search argument, citing consent was legally obtained from Rawls and his mother. The Court ruled Rawls, a co-owner of the gym bag, was authorized to give consent to search the bag, even though items in certain compartments of the bag belonged to Frazier.
Subsequent history
Later case law has interpreted Frazier v. Cupp as the case permitting police deception during interrogations. The Court stated,The fact that the police misrepresented the statements that Rawls had made is, while relevant, insufficient, in our view, to make this otherwise voluntary confession inadmissible.
The language of the ruling did not specifically state which forms of police deception were acceptable, but the ruling provided a precedent for a confession being voluntary even though deceptive tactics were used.
See also
- List of United States Supreme Court cases, volume 394
- List of United States Supreme Court cases
- Escobedo v. IllinoisEscobedo v. IllinoisEscobedo v. Illinois, 378 U.S. 478 , was a United States Supreme Court case holding that criminal suspects have a right to counsel during police interrogations under the Sixth Amendment. The case was decided a year after the court held in Gideon v...
(1964) - Miranda v. ArizonaMiranda v. ArizonaMiranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
(1966)
Further reading
- Inbau, F.E., Reid, J.E., Buckley, J.P., & Jayne, B.C. (2004) Criminal interrogation and confessions. Sudbury, MA: Jones and Bartlett Publishers.
- Magid, L. (2001). Deceptive police interrogation practices: How far is too far? Michigan Law Review, 99, 1168-1210. Retrieved from http://www.jstor.org/stable/1290529.
- Sasaki, D.W. (1988) Guarding the guardians: Police trickery and confessions. Stanford Law Review, 40, 1593-1616. Retrieved from http://www.jstor.org/stable/1228783.