State v. Reid

In this criminal appeal, Donta Reid challenges the trial court’s failure to suppress his confession, arguing it was obtained in violation of his Sixth Amendment right to counsel. We disagree and find the facts of Reid’s case fall within the purview of Montejo v. Louisiana, 556 U.S. 778, 129 S.Ct. 2079, 173 L.Ed.2d 955 (2009), in which the United States Supreme Court held a valid Miranda 1 given waiver prior to a custodial interrogation sufficed to waive a defendant’s Sixth Amendment right to counsel regardless of whether he retained representation at a prior arraignment. Id. at 795, 129 S.Ct.…