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The Meaning of Rothgery:
I'm trying to understand this morning's important Sixth Amendment decision in Rothgery v. Gillespie County, and in particular the key practical question raised by the case: When exactly does the Sixth Amendment attach, and what does that mean? The opinion is clear that it only addresses the first question: It goes out of its way to say that the opinion does not answer what it means for the Sixth Amendment right to attach when there is no hearing pending (see slip op at 20). But I'm having a little trouble understanding exactly when the right to counsel now attaches.

  The Court states its holding in Rothgery as follows:
[A] criminal defendant's initial appearance before a judicial officer, where he learns the charge against him and his liberty is subject to restriction, marks the start of adversary judicial proceedings that trigger attachment of the Sixth Amendment right to counsel.
  I am not a Sixth Amendment expert, so I have a few questions for those who are: Does this mean that there must be counsel before a detention hearing occurs, or perhaps afterwards? If it means there must be counsel before the detention hearing, how is Rothgery consistent with the Sixth Amendment discussion in Gerstein v. Pugh, where the Court indicated that "pretrial custody may affect to some extent the defendant's ability to assist in preparation of his defense," but that a probable cause hearing did not trigger a critical stage requiring a constitutional right to counsel? Is the idea that there is an abstract right at that stage but that the lawyer doesn't actually need to be present for the hearing? And if a person is arrested on a warrant, does the crime named in the warrant count as "the charge against him"? Are all initial appearances now enough to trigger the Sixth Amendment right to counsel, or is the gist of Rothgery that there must be counsel appointed before any detention after the initial 48 hour window?
bornyesterday (mail) (www):
IANAL, and maybe I was my screen name, but I've always been under the impression that the rights guaranteed by the Constitution and Bill of Rights were inherent and didn't only come into effect in certain situations, though they might be limited in some situations (ie. speech, etc).
6.23.2008 12:48pm
Ilya Non-Somin:
Alito's concurrence seems to say Orin's question was not raised by the petitioner and hence not addressed by the Court. Rather, Alito points out that the Court merely answers when the right to Assistance of Counsel attaches, but does not address what Assistance of Counsel under the facts would be.
6.23.2008 12:58pm
Kenvee:
bornyesterday,

The Sixth Amendment has a built-in limitation, though. It only applies to "criminal proceedings." The question is when the criminal proceeding begins, thus when the right attaches. No criminal proceeding, no right, straight from the Founders themselves.

As a Texas practitioner, I've been interested in the result of this case. I'm still not sure how exactly it applies. As Alito pointed out, the Court seemed to be making a point of trying to limit the issue, and it is inherently limited from the standpoint of just deciding a threshold issue of a summary judgment denial. I don't know how much impact it'll have in practice.
6.23.2008 1:42pm
Kent Scheidegger (mail) (www):
Justice Souter's opinion says, "Our holding is narrow," and indeed it is very narrow. As Justice Alito's concurrence notes, a finding that the right to counsel has "attached" means only that counsel must be present for "critical stages," which are events where counsel needs to be present to preserve rights related to the forthcoming trial. There is, to date, no Supreme Court precedent that requires appointment of counsel for indigent defendants to protect rights other than trial. More on this at Crime and Consequences.
6.23.2008 1:46pm
Anderson (mail):
Does this mean that there must be counsel before a detention hearing occurs, or perhaps afterwards?

Yeah, it's pretty sad if they didn't get that straight -- I appreciate judicial restraint &all, but cases are expensive and slow to litigate up to the high Court.

OTOH, look at that majority! Wooo!
6.23.2008 2:07pm
bornyesterday (mail) (www):
Kenvee - that's a good point. Hadn't thought of it like that.
6.23.2008 2:11pm
OrinKerr:
Ilya Non-Somin,

I agree, and I believe I say that in my first paragraph. That's why my post is about the first question rather than the second one.
6.23.2008 2:15pm
American Psikhushka (mail) (www):
Kent-

I read your linked essay and it makes sense. I'm assuming that you think detention or imprisonment for any extended period would trigger the right as well, seeing as how the right of habeas corpus is essentially worthless without counsel to see to its exercise. This would also seem to involve Kenvee's point about criminal versus civil proceedings. One would think that any extended period of detention or imprisonment, even if the alleged mechanism is "civil", would trigger the habeas right and therefore the right to counsel. But then again we are through the looking glass into Neocon-land these days, so who knows. Any thoughts?
6.23.2008 3:01pm
American Psikhushka (mail) (www):
Going over Orrin's post again the Court seems to think that any time a defendant knows his "liberty is under restriction" the right seems to attach. Although it is not clear whether this has to be in the context of being formally charged. One would assume it does attach when liberty is being restricted, but again we are living in "interesting times".
6.23.2008 3:10pm
Dave N (mail):
Umm,

American Psikhushka, there is no right to counsel in habeas corpus. None. Zip. Nada. Now, a court, in its discretion. may choose to appoint counsel in habeas proceedings, but that is very different from stating that there is a right to counsel in habeas proceedings.

By the way, I agree with Kent Scheidegger that this is a very narrow holding and actually answers very little.
6.23.2008 3:26pm
omarbradley:
I think Thomas' opinion was more persuasive in this case
6.23.2008 4:22pm
Jacob Berlove:
Does this mean that there must be counsel before a detention hearing occurs, or perhaps afterwards?

Afterwards. Only after the conclusion of the hearing, when the defendant has formally been notified of what s/he has been accused of, does the majority consider the "criminal prosectuion" to have been commenced.

Are all initial appearances now enough to trigger the Sixth Amendment right to counsel, or is the gist of Rothgery that there must be counsel appointed before any detention after the initial 48 hour window?

According to the majority, "under the federal standard, an accusation filed with a judicial officer is sufficiently formal, and the government's commitment to prosecute it sufficiently concrete, when the accusation prompts arraignment and restrictions on the accused's liberty to facilitate the prosecution." (Slip opinion at 17).

In any event, the 48 hour window certainly has nothing to do with attachent of the right. County of Riverside simply set 48 hours as the time the government has to take a defendant to a probable cause hearing without facing the burden of proof that the delay was unavoidable. In those cases, the defendant has the burden of proof that the delay was unnecessary. But this presumption doesn't set a de jure 48 hours from arrest after which an arrest simpliciter automatically becomes a formal accusation against the arrestee, and I can't see anything in this opinion that implies that the right to counsel will attach in the event that the government violated the arrestee's due process right to a prompt probable cause determination. It is the determination itself, not the constitutional requirement of having one take place that triggers the right to counsel.
6.23.2008 4:29pm
OrinKerr:
Jacob,

So there's no right to an attorney to detain you, but after you're put in detention without an attorney, you then have a right to an attorney so he can . . . what exactly?
6.23.2008 4:44pm
Jacob Berlove:
Omarbradley,

I'm not completely convinced by Justice Thomas's opinion even as an original matter. The text of the amendment reads "in all criminal prosecutions", and the argument can be made that the culmination of a proceeding that sets the course of prosecution, or "the matter of formal accusation" in motion suffices to trigger the right, sufficient to be considered "in" a criminal prosecution. It is true that the self incrimination right is phrased differently "in all criminal cases", but that can be explained by pointing to its applicability even before the probable cause determination has been completed; indeed, the right applies even before arrest should the defendant choose to assert it, at least as long as a case can be made that the defendant has a reasonable fear of prosecution. See e.g. Hiibel. And in Chavez v. Martinez, Justice Scalia took the view that all the right not to be subject to self incrimination entails is the right not to have the evidence used against you, not the right not to have it extracted in the first place. If Justice Scalia is right, then the different phraseology of the fifth amendment's self-incrimination clause is anyway's explainable. In sum, I don't agree with the Chief Justice and Justice Scalia that Justice Thomas's case is "compelling" at all.
6.23.2008 4:49pm
Jacob Berlove:
Prof. Kerr,

The question was left open by the majority opinion, and Justice Alito's concurrence strongly implies that he would have ultimately found that the temporal right to an attorney subsequent to the Texas hearing would have done Rothgery no good. As Justice Alito's concurrence explains, the right only guarantees the defendant an attorney for any "critical stage [n]ecessary to guarantee effective assistance at trial" (slip opinion at 5), which apparently includes "preliminary hearing[s] where "substantial prejudice inheres in the confrontation" and "counsel [may] help avoid that prejudice" (slip opinion at 4-5), as well as pretrial lineups, pretrial interrogations, and pretrial psychiatric exams. (Slip opinion at 5). The concurrence storngly implied that the substantive right to an attorney didn't really exist here, and I suspect the majority (or at least some of the majority) would agree; SCOTUS granted cert only to address the temporal question, and the substantive question was remanded because the fifth circuit, having found against the defendant on the temporal question, never had an opportunity to address the substantive one.
6.23.2008 5:03pm
Originalism Is Useful (mail):
Jacob,

So there's no right to an attorney to detain you, but after you're put in detention without an attorney, you then have a right to an attorney so he can . . . what exactly?



Lay you down and give you that good lovin'
You know everybody needs some good huggin'
A bottle of wine, and blanket for my boo
You what I am gonna do...
Makin' that love



Oh, sorry. Wrong thread.
6.23.2008 5:12pm
George Weiss (mail) (www):
Orin:

Ilya non somin" has it right...at least as far as Alito's concurrence explains the opinion-and Alito's concurrence is backed up by language from the opinion.



Alito's concurrence basically says

a) appointment of counsel has attached (at least at the time of the initial appearance-(and probably before)
b) the fact that a right exists past that point doesn't mean it applies-must still be enough adversarial/defense work to do to create need for counsel
c)Rothgery never raised issue of whether there was enough adversarial/defense work (enough-"going on") to require appointment
d) we remand on that issue-having told the lower courts they now must reach it since, contrary to what they thought-"the sixth amendment has attached"

It is consistent with Gerstein-by reading Gerstein as saying that an initial appearance doesn't necessarily trigger right to appointment (even though the sixth has certainly 'attached'). Gerstein, according to this new reading, is now simply saying that the initial appearance itself is not enough to have enough "going on" to necessitate counsel.


the majority does indeed seem to be saying this:


"Our holding is narrow. We do not decide whether the 6-
month delay in appointment of counsel resulted in prejudice
to Rothgery's Sixth Amendment rights, and have no
occasion to consider what standards should apply in deciding
this.....Because the Fifth Circuit came to a different conclusion
on this threshold issue, its judgment is vacated, and
the case is remanded for further proceedings consistent
with this opinion."



I would say what's important about the decision is striking down the notion that there is some limitation to appointing counsal when there is no prosecutor in the case. I.E., according to the prosecution, even if theres avesarial work to be done by a defense attorney-since there is no prosecutor-we need not reach the question of whether we have reached an adversairal/important for defense stage. After all-it might well be that there is a lot of impportant work for the defense-but why worry-the state has noone on its side to help it either.

Indeed. there might be much defense work to be done prior to the initial appearence. But that doesnt mean you get a lawyer-your not far enough along-the right hasn't "attached".

This case dispells that notion. It says that as long as there is adverasril work to be done-the right to counsal being appointed startes (at least) at the time of initial appearence-regardless of whehter there is a prosedcutor invovled.

As Alito (and I think the opinion) make clear (consistant with gerstein) however, just because a right has attached, doesn't mean it always applies. There is that other issue of there being enough work for defense to do to make it constituitonally neccesary. The court here doesn;t deal with this other issue.

Thus gerstein is consitant with this case becuase it does deal with the other isse. It says that the simple fact that there is a probable cause hearing doesn't mean theres enough work to do to appoint a defense counsal. There might be, but maybe not.

Indeed, in Rothgery's case, maybe, maybe not. But it isnt for the court to decide.

Thus, I think Ilya non-somin was right for telling you Alito deals with your question. Your post seems to auotmatically equate the right to appearence of counsal and the "right attaching."
6.24.2008 1:04am
Narmy Potamus (mail):
The 6th amendment gives a citizen the right [...] to have the Assistance of Counsel for his defence.

The court says the right attaches at the 15.17 hearing.

So the real question is: "When does the defense begin?"

And the answer depends on the case. Some defendants exercise their right to remain silent. Others deny the charges to arresting officer and ask for an attorney. If the defendant denies the validity of probable cause affidavit presented to the magistrate, and he asked for the assistance of an attorney. He should have the assistance of an attorney. If he just stands there an nods then oh well.
6.24.2008 12:43pm
American Psikhushka (mail) (www):
Dave N-

American Psikhushka, there is no right to counsel in habeas corpus. None. Zip. Nada. Now, a court, in its discretion. may choose to appoint counsel in habeas proceedings, but that is very different from stating that there is a right to counsel in habeas proceedings.

What are you talking about? Are you telling me that all habeas proceedings are handled by jailhouse attorney defendants for themselves - they file their own petitions, appear on their own behalf, make their own arguments, etc.? Or do federal judges just comb through the system for habeas situations to hear on their own?

No, what happens is that they've already had counsel appointed or retained counsel on their own at some point earlier in the process and their counsel decides to file a habeas petition.

The hypothetical that some were implying in the discussion was what would happen if you had a situation where there was a dubious detention by the government and either the state hadn't done anything to trigger the right to counsel (other than the detention itself) or that the state had done things to trigger the right to counsel but wouldn't appoint counsel. Let's construct a hypothetical:

The county sheriff has it in for you because you broke up with her sister - let's say her sister smelled bad and talked incessantly about American Idol. So the sheriff says something about "terrorism" to her deputies and has them arrest you and throw you in the detention center. You've been in your cell for three days and they don't formally question you or have any proceedings where the charges are presented or bail is set. Any time you see a deputy when you say you want to see your attorney they just look away and mumble something about "terrorism". To reference the quote from the opinion above, you haven't heard the charges against you before a judicial officer, but your liberty is definitely been restricted. Are you claiming that there is no right to counsel in this situation? They can hold you indefinitely without cause at the whim of a law enforcement official as long as they don't interrogate you or tell you what the charges are in front of a judge?
6.24.2008 2:53pm
MJG:
I need to go over this some more, as I am not an expert on this aspect of the Sixth Amendment, but I will say I was surprised at how wide the gap Justice Alito sees between the right to counsel "attaching" and the point at which you actually have the right to have, meet with, or confer with your counsel. I understand the point that there may be little for counsel to do, but it seems odd to say that the right (which simply refers to assistance of counsel in criminal prosecutions) attaches but that legal fiction takes on no reality until some later point when we think its more salient for your trial that you have counsel. But I need to go over this more.
6.25.2008 12:12am
Philly Buster:
The law doesnt say "right to counsel at trial." It doesnt say anything about trial.

The law says right to counsel to assist in your defense of a criminal prosecution. If the court says the criminal prosecution begins when you hear the charges against you then, if you want an attorney's assistance defending yourself "pre-trial" then you should have that right.

Rothgery himself was ultimately freed because of his attorney's pre-trial work.
6.25.2008 4:16am
Jimbeaux (mail):
American,
My answer would be that your hypothetical presents a Fourth Amendment problem, not a Sixth Amendment problem. You've essentially got someone who's been arrested without probable cause. And a law enforcement officer who's done what you've suggested probably wouldn't be interested in vindicating your rights under whatever 15.17-type arraignment statute your state has.
6.25.2008 6:53pm
AmyinTexas (mail):
As a Texas resident, I think it's important to state clearly the abysmal denial of due process in this state. Many people are confused about this decision because they can't imagine such deprival of due process exists in the USA. But it does in Texas

In Texas a person can be arrested, jailed, pay bail, or remain in jail, and have charges pending for as long as a year and a half before the state officially "decides to prosecute." There is no probable cause hearing. The accused isn't present at any hearings or discussions between their attorney and the district attorneys prior to being jailed. Their attorney cannot be present at their arrest and posting of bail. Thousands of people who commit routine traffic violations are put through the same arrest process. District Attorneys can feign inattention, and hold all the cards. The whole process involves a lot of fear and inability on the part of the accused to be advocated or acted for by an attorney.

I believe that there are some Texas laws written to give the appearance of probably cause hearings such as http://law.onecle.com/texas/criminal-procedure/15.17.00.html
In this law, supposedly the accused is supposed to appear before a magistrate within 48 hours after arrest.

In practice, what actually happens is the accused is told that if they insist on such a hearing, they can be held in jail indefinitely, while if they accept and pay bail (determined at a 'hearing' between a policeman, a judge, and sometimes a DA without the accused or their attorney present), or if they accept being jailed due to inability to pay bail, the system will be much easier on them. They are usually not clearly told the charge, and if they ask to have it explained they are rebuffed.

As a result, someone with a friend in the police department can file a false charge such as "criminal trespass" (being on someone's property for longer than 30 seconds after they tell you to leave - basically, the way its used) and an arrest warrant can be issued, the accused jailed (or bailed). Then the state pretends it still hasn't made a decision - information about why the charges are being filed, documenting evidence, etc., can be withheld many weeks due to excuses of technical difficulties, or vacations, etc. Thus Souters comments

"And it would have the practical effect of resting attachment on such absurd distinctions as the day of the month an arrest is made, see Brief for Brennan Center of Justice et al. as Amici Curiae 10 (explaining that "jails may be required to report their arrestees to county prosecutor offices on particular days" (citing Tex. Crim. Proc. Code Ann., Art. 2.19)); or "the sophistication, or lack thereof, of a jurisdiction's computer intake system," Brief for Brennan Center, supra, at 11; see also id., at 10--12 (noting that only "[s]ome Texas counties … have computer systems that provide arrest and detention information simultaneously to prosecutors, law enforcement officers, jail personnel, and clerks. Prosecutors in these jurisdictions use the systems to prescreen cases early in the process before an initial appearance" (citing D. Carmichael, M. Gilbert, &M. Voloudakis, Texas A&M U., Public Policy Research Inst., Evaluating the Impact of Direct Electronic Filing in Criminal Cases: Closing the Paper Trap 2--3 (2006), online at http://www.courts.state.tx. us/tfid/pdf/FinalReport7-12-06wackn.pdf (as visited June 19, 2008, and available in Clerk of Court's case file))).



I believe the real and resounding reason for the decision was to stop this two stage process of criminal charges in Texas. Right now (or until this decision) in Texas a person can/(could?) be accused, arrested, charged bail or held in jail, without the benefit of appearing before a judge for a hearing, or having an attorney represent them. Its a Stalinist system. The level of abuse depends on the County - more civilized places like Dallas, Austin and Houston tend to behave less egregiously, but in smaller counties that have corrupt police departments, old boy networks, and Jim Crow influence, you get a situation where a false charge can ruin someone's life, keep them in jail, cause them to lose their job, make them lose thousands of unrefunded dollars to post bail, long before there is anything approaching a probably cause hearing.

The approach Gillespie County was taking in this suit is common in Texas. It is completely disingenuous, but there is a pretended air of disorganization, incompetence, inability to follow through on things, egregious mistakes being accepted as routine, etc. which leads to the deprival of due process.

Most frighteningly, the accused is COMPLETELY dependent on their attorney, and doesn't even witness the discussions pertaining to their cases dismissal or subsequent move to trial between the DA and their lawyer. The accused can be completely invisible until a trial begins, and ignored by the DA until that moment.
6.28.2008 3:34pm
AmyinTexas (mail):
I should add that I have heard anecdotally in Texas that many "defense" attorneys actually collaborate with the DAs and decide their clients fate during these meetings when the client isn't present. I know people who have had the experience of not having their defense attorney act as their advocate - but rather being someone who scares them into submitting to a charge with no probable cause. Now, some of the best defense lawyers in the world are in Texas -I don't mean all aren't looking out for their clients interests.

But but you can't look at this system without realizing that a lot of people are making a lot of money (especially the bail bondsmen)from this system where the accused can be jailed withou representation or probable cause hearings.

Its a system that's asking to be corrupted. Imagining the possibilities for kickbacks is terrifying.
6.28.2008 3:43pm
AmyinTexas (mail):
To clarify: your attorney isn't even allowed to talk to the DA until after you've been arrested and jailed.
6.28.2008 3:44pm
AmyinTexas (mail):
I'd like to add that this lack of due process means many cases actually go to trial that never should. For example, this case from my city where a newspaper photographer was arrested for "criminal trespass" because he was photographing police beating up a 'suspect' in a public place during Mardi Gras:

Police arrest photographer, delete his photos

Police put photographer through trial for trespass (at public Mardi Gras) after deleting his photos


And here are some cautionary tales of what can happen (in a small city of 58,000) when the power of the police is unchecked by due process (reference this link:

problems of unchecked police power in small Texas city

If you read the link, you need to scroll down, or read the excerpt below



May 2008: Texas Rangers are investigating the disappearance of about $18,000 in cash and drugs from the GPD property room. The District Attorney was forced to drop 16 cases because of the loss of evidence.

May 2008: Moses Mitchell, a young black man riding his bike home from work, is jailed overnight for an unpaid ticket for an unregistered bicycle. Many saw the incident as one more example of racial profiling run amok.

April 2008: Capt. Phillip Morris is named interim police chief after the sudden resignation of Chief Kenneth Mack, who took over the post in May 2005. The Daily News has requested documents regarding Mack's unexplained resignation, but we're still fighting to get everything we asked for. Neither Mack nor city manager Steve LeBlanc will answer questions.

March 2008: After a riot breaks out following a seawall spring-break rap concert, many residents cry foul. The exact same thing happened last year. When the newspaper complained that police should have planned better, LeBlanc defended his troops, saying the riot had occurred after a careful plan. This failed to reassure some people.

Jan. 2008: Two GPD officers are fined and given suspensions for horsing around in the new county law-enforcement center. The two men fired a pellet gun indoors, setting off a sprinkler system that did $170,000 in damage to the spanking new facility.

Oct. 2007: A GPD officer files suit against the city, claiming she had been subjected to retaliation and sexual discrimination after complaining about a racy Christmas party skit from the previous year.

Aug. 2007: Galveston City Council announces a budget showing a whopping increase of 7 percent. The biggest increase went to Galveston policemen, whose pay increased $1.7 million in the budget year. Civilian employees not represented by the politically powerful police union got a 3 percent raise.

July 2007: The Galveston County Coalition for Justice meets to discuss what it calls an ongoing problem of police brutality against minorities in Galveston. Leon Phillips, vice president of the group, said he had written accounts and photos of seven separate incidents. Tarris Woods, who is now a city councilman, wrote a column for the group citing police brutality and racial profiling as its top priorities.

March 2007: A member of Galveston's ethics commission asks police and city officials for a full investigation of the arrest of a former health-club owner. That came after a trial in which the arrested man, Ryan Sullivan, was acquitted of charges that he had assaulted a police officer. Sullivan said he was himself assaulted.

Feb. 2007: Galveston County Daily News photographer Nick Adams is thrown to the ground, arrested and placed in jail for "interfering with a police officer." He was photographing an arrest at Mardi Gras at the time. Adams was acquitted of the charge last week in Galveston. While he was in GPD custody, someone erased digital photo evidence from his camera.

Aug. 2006: Two police offices are suspended for working second jobs. That's common practice, but these two were alleged to have been on the clock simultaneously for the city.

Aug. 2005: After a charge of police brutality in the arrest of Michael Bouliane, GPD battles requests for documents relating to charges of police brutality in Galveston. At that time, police acknowledged there had been 54 charges of brutality brought against GPD officers in the previous five years. At least some of those were found to be true, police said. The records never were released.

July 2005: Protesters demonstrate at Galveston City Hall against police brutality.

July 2005: Police Chief Kenneth Mack, who now seems to have disappeared himself, reports back to city council that "the physical and chemical force used to subdue Mr. (Patrick James) Woods (in June 2005) were necessary and reasonable." No one on the city council questioned that or asked to see the evidence upon which that conclusion was based.

June 2005: A Galveston woman reports that she saw Galveston police officers beat and kick a man while he lay on the ground. That man was Patrick James Woods, and the case came to be discussed more publicly than the scores of similar complaints filed in Galveston. The woman witness was Sheridan Lorenz, daughter of billionaire oilman and developer George Mitchell.

June 2005: In that same month, police also investigate a complaint filed by James Bouliane that he was roughed up while being held in handcuffs at Galveston Police headquarters.

March 2004: GPD officers participate in the formation of a political action committee, the Citizens and Labor for Good Government. The PAC spent its time attacking city manager Steve Le Blanc and lobbying for more pay and benefits for GPD officers.



And in response to American P's hypothetical:
The county sheriff has it in for you because you broke up with her sister - let's say her sister smelled bad and talked incessantly about American Idol. So the sheriff says something about "terrorism" to her deputies and has them arrest you and throw you in the detention center. You've been in your cell for three days and they don't formally question you or have any proceedings where the charges are presented or bail is set. Any time you see a deputy when you say you want to see your attorney they just look away and mumble something about "terrorism". To reference the quote from the opinion above, you haven't heard the charges against you before a judicial officer, but your liberty is definitely been restricted. Are you claiming that there is no right to counsel in this situation? They can hold you indefinitely without cause at the whim of a law enforcement official as long as they don't interrogate you or tell you what the charges are in front of a judge?


that kind of thing happens in Texas all the time - through disingenuous processes as I described above
6.28.2008 5:10pm