Facts of the Case
Hazel Morrison was indicted for distributing heroin and obtained private counsel for her defense. Without her counsel's knowledge two agents of the Drug Enforcement Agency (DEA) conversed with her regarding a related investigation. During this conversation the agents advised that she have a public defender represent her instead of her private counsel. They also told her that the severity of her punishment would depend on how well she cooperated with them. Morrison notified her counselor immediately and did not speak to the agents about the investigation. She unsuccessfully petitioned the District Court to dismiss her indictment on the ground that the agents had violated her Sixth Amendment right to counsel. Morrison then entered a guilty plea to one count of the indictment. On appeal the Court of Appeals for the Third Circuit found that Morrison's Sixth Amendment rights had been violated and ruled to drop all charges against her.
Questions
Did the United States Court of Appeals for the Third Circuit wrongfully dismiss criminal charges on the ground that the defendant's Sixth Amendment right to counsel was violated in a way that had no tangible effect upon court proceedings?
Conclusions
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Yes. Justice Byron White authored the opinion for the Court unanimously reversing the Third Circuit's decision. For sake of argument, the Court granted that Morrison's Sixth Amendment right to counsel had been violated, but held that this did not merit the dismissal of all charges since the conduct of the agents did not prejudice the outcome of the trial. The Court maintained that Sixth Amendment violations should not be remedied beyond the scope of the harm they inflicted upon the defendant.