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The Police-Prosecutor Relationship and the No-Contact Rule: Conflicting Incentives After Montejo V

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The Police-Prosecutor Relationship and the No-Contact Rule: Conflicting Incentives After Montejo V Cleveland State Law Review Volume 58 Issue 4 Article 3 2010 The Police-Prosecutor Relationship and the No-Contact Rule: Conflicting Incentives after Montejo v. Louisiana and Maryland v. Shatzer Caleb Mason Southwestern Law School Follow this and additional works at: https://engagedscholarship.csuohio.edu/clevstlrev Part of the Constitutional Law Commons, and the Criminal Procedure Commons How does access to this work benefit ou?y Let us know! Recommended Citation Caleb Mason, The Police-Prosecutor Relationship and the No-Contact Rule: Conflicting Incentives after Montejo v. Louisiana and Maryland v. Shatzer, 58 Clev. St. L. Rev. 747 (2010) available at https://engagedscholarship.csuohio.edu/clevstlrev/vol58/iss4/3 This Article is brought to you for free and open access by the Journals at EngagedScholarship@CSU. It has been accepted for inclusion in Cleveland State Law Review by an authorized editor of EngagedScholarship@CSU. For more information, please contact [email protected]. THE POLICE-PROSECUTOR RELATIONSHIP AND THE NO-CONTACT RULE: CONFLICTING INCENTIVES AFTER MONTEJO V. LOUISIANA AND MARYLAND V. SHATZER CALEB MASON* I. INTRODUCTION .................................................................... 748 II. THE NEW CASES .................................................................. 750 A. Montejo........................................................................ 750 B. Shatzer ......................................................................... 752 C. Restatement of the New Rule ....................................... 754 III. THE NO-CONTACT RULE ..................................................... 755 A. Background.................................................................. 755 B. What Does “Authorized by Law” Mean?.................... 757 C. Undercover Investigations........................................... 759 IV. FOUR SCENARIOS: MONTEJO AND SHATZER, PRE- AND POST-ATTACHMENT ............................................................ 763 A. Pre-Attachment Montejo Contacts .............................. 763 1. Police.................................................................... 763 2. Prosecutor............................................................. 763 B. Post-Attachment Montejo Contacts............................. 765 1. Police.................................................................... 765 2. Prosecutors ........................................................... 765 C. Pre-Attachment Shatzer Contacts................................ 766 1. Police.................................................................... 766 2. Prosecutors ........................................................... 766 D. Post-Attachment Shatzer Contacts .............................. 767 1. Police.................................................................... 767 2. Prosecutors ........................................................... 767 E. Discussion.................................................................... 767 V. DIVERGING INCENTIVES AND THE POLICE-PROSECUTOR RELATIONSHIP ..................................................................... 769 A. Agency Priorities ......................................................... 770 B. Training, Supervision, and Direction.......................... 771 VI. PRACTICAL CONSEQUENCES FOR DEFENDANTS ................... 776 VII. CONCLUSION ....................................................................... 778 * Associate Professor of Law, Southwestern Law School. Assistant United States Attorney, Southern District of California, 2007-09. J.D., Georgetown, Ph.D.; (Philosophy), Columbia. 747 Published by EngagedScholarship@CSU, 2010 1 748 CLEVELAND STATE LAW REVIEW [Vol. 58:747 I. INTRODUCTION In two recent cases, Montejo v. Louisiana1 and Maryland v. Shatzer,2 the Supreme Court has held, for the first time, that overt custodial government contact with a represented criminal defendant after the Sixth Amendment right to counsel has attached, initiated by law enforcement agents for the purpose of securing a Miranda waiver and obtaining a statement and without the consent or presence of the defendant’s lawyer, is constitutional in certain circumstances. This change in the constitutional landscape has serious implications for the interpretation and enforcement of one of the bedrock rules of professional responsibility: the rule that lawyers are forbidden from making contact with represented adverse parties.3 It forces the question: Should the ethics rules be aligned with the constitutional rules in criminal cases? And if they diverge, can prosecutors effectively manage their investigations when key investigatory tactics are lawful for police but forbidden for prosecutors? In the parallel context of undercover investigations, in which prosecutors direct undercover agents to elicit incriminating statements from represented defendants, the courts have uniformly interpreted the no-contact rule to allow for undercover contacts prior to the initiation of adverse judicial proceedings and the attachment of the Sixth Amendment right to counsel. But no court, commentator, or committee has ever announced or proposed such a rule for overt contacts. Before Montejo and Shatzer, there was no need to consider the question because the Miranda rules4 tracked the ethical rules by way of Michigan v. Jackson.5 But things have now changed. Jackson has been overruled, and Montejo and Shatzer force us to reconsider the standard analyses of the constitutional and ethical norms governing the following four scenarios, as applied to police and to prosecutors: 1) In systems—paradigmatically, federal court—in which counsel is appointed for defendants at their initial appearance, but the Sixth Amendment does not attach until an indictment or information is filed (up to thirty days later), may law enforcement custodially contact the defendant, post-appointment but pre-attachment, without counsel present, in the attempt to get a Miranda waiver, so long as the defendant has not invoked a right to counsel in a Miranda setting? And may a prosecutor ethically direct or supervise agents in so doing? 2) May law enforcement custodially contact a represented criminal defendant post-attachment, where the defendant has been appointed counsel at an initial appearance but has not invoked his right to counsel in a Miranda setting? 1 Montejo v. Louisiana, 129 S. Ct. 2079, 2086 (2009). 2 Maryland v. Shatzer, 130 S. Ct. 1213, 1222 (2010). 3 MODEL RULES OF PROF’L CONDUCT R. 4.2 (2009) (enacted more or less verbatim in every state code). 4 Miranda v. Arizona, 384 U.S. 436, 471-72 (1966). 5 Michigan v. Jackson, 475 U.S. 625, 636 (1986). https://engagedscholarship.csuohio.edu/clevstlrev/vol58/iss4/3 2 2010] THE POLICE-PROSECUTOR RELATIONSHIP 749 And may a prosecutor ethically direct or supervise agents in so doing? 3) May law enforcement custodially contact a defendant, pre-attachment, in the attempt to get a Miranda waiver, where the defendant has invoked his right to counsel in a Miranda setting but has then been released from custody for two weeks? And may a prosecutor ethically direct or supervise agents in so doing? 4) May law enforcement custodially contact a defendant, post-attachment, in the attempt to get a Miranda waiver, where the defendant has invoked his right to counsel in a Miranda setting but has then been released from custody for two weeks? And may a prosecutor ethically direct or supervise agents in so doing? In this paper, I examine the consequences of the divergence of ethical and constitutional rules, with particular attention to the institutional dynamics of criminal investigation and specifically the relationship between police and prosecutors. This relationship is of crucial importance because Montejo and Shatzer create a legal regime in which non-lawyer agents and officers may initiate investigative contact with represented defendants in circumstances in which prosecutors are absolutely forbidden to do so. This situation undermines the ability of prosecutors to effectively supervise the investigation of their cases and puts them in an untenable position when advising agents on the law. In Part II of this paper, I set out the facts and holdings of the new cases. In Part III, I explain the scope and limits of the no-contact ethics rule as applied to criminal investigations. In Part IV, I apply the constitutional and ethical rules to four specific investigatory scenarios to show how the legal limits on police and prosecutorial investigations diverge. In Part V, I examine the potential consequences of divergent rules for police and prosecutors on permissible investigative methods. In Part VI, I consider the likely practical consequences of the new cases for defendants. I conclude that rather than lower the ethical bar for prosecutors, prosecuting agencies should raise the bar for their agents: Prosecutors should instruct their agents not to make Montejo/Shatzer contacts with defendants and should commit to a policy of not using any Montejo/Shatzer statements nonetheless obtained by law enforcement. Such a policy—already endorsed by the Justice Department for federal agents6—is, I think, necessary to maintain the integrity of the adversarial process, which is necessary for maintaining the social legitimacy of law enforcement. 6 See Brief for the United States as Amicus Curiae in Support of Overruling Michigan v. Jackson at 11-12, Montejo v. Louisiana, 129 S. Ct. 2079 (2009) (No. 07-1529), 2009 WL 1019983 (stating that federal agents are unlikely to engage
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