Michigan V. Jackson - Aftermath

Aftermath

The holding in Michigan v. Jackson was narrowed later by the Court in McNeil v. Wisconsin, 501 U.S. 171 (1991), which held that an accused's invocation of his Sixth Amendment right to counsel during a judicial proceeding does not constitute an invocation of the right to counsel derived by Miranda v. Arizona, 384 U.S. 436, from the Fifth Amendment's guarantee against compelled self-incrimination. "Therefore, while a defendant who has invoked his Sixth Amendment right to counsel with respect to the offense for which he is being prosecuted may not waive that right, he may waive his Miranda–based right not to be interrogated about unrelated and uncharged offenses." Also the Court held in Michigan v. Harvey, 494 U.S. 344 (1990), that evidence acquired in violation of Michigan v. Jackson could be used for impeachment purposes.

Rudy Bladel was retried, found guilty and sentenced to three concurrent life sentences with no possibility of parole added to the sentence. He died in Jackson, Michigan on November 15, 2006 of thyroid cancer.

On March 27, 2009, the Supreme Court ordered lawyers in a pending case, Montejo v. Louisiana, (Docket No.07-1529), to file new briefs on whether the Court should overrule its decision in Michigan v. Jackson. On May 26, 2009 the Supreme Court overruled Michigan v. Jackson through the Court's decision in Montejo v. Louisiana.