Samantha Bachynski v. Anthony Stewart, 813 F.3d 241

Samantha Bachynski and an accomplice brutally murdered three victims; police arrested Bachynski with physical evidence linking her to the crimes (fingerprints on duct tape, bloody/bleached sweatshirt, in driver’s seat of stolen truck with a body in the bed).
At booking Bachynski invoked her Miranda right to remain silent and asked for an attorney; officers did not initially question her.
Detectives later returned, offered a phone and phone book to help her contact counsel; Bachynski expressed uncertainty and then said, pointing to an officer, “I want to talk to you.”
After the officers obtained prosecutorial approval they read Miranda warnings again, Bachynski signed waivers three separate times and confessed multiple times; statements were admitted at trial and she was convicted of first-degree murder and sentenced to life without parole.
On direct appeal Michigan courts upheld admission of the confessions, finding Bachynski initiated the conversations and validly waived counsel; a federal district court granted habeas relief on the Fifth Amendment claim, and the State appealed to the Sixth Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers impermissibly initiated interrogation after invocation of right to counsel	Bachynski: officers’ cell visit and alleged comments (e.g., co-defendant talking; threats about accomplice) were the functional equivalent of interrogation and coerced her to speak	State: officers merely provided tools to contact counsel; any comments did not amount to interrogation and state courts found officers focused only on facilitating counsel	Court: State courts reasonably concluded no interrogation occurred; officers’ conduct was not clearly likely to elicit incriminating response
Whether Bachynski validly waived her Miranda rights after initially requesting counsel	Bachynski: post-invocation waiver was coerced/invalid due to psychological pressure and officers’ statements	State: multiple rereadings of Miranda, signed waivers, explicit statements she changed her mind show voluntary, knowing waiver	Court: waiver was valid — she knowingly and voluntarily waived rights and signed waivers multiple times
If any Miranda error occurred, whether it was harmless	Bachynski: confessions were central and prejudicial	State: overwhelming independent evidence of guilt made any error harmless	Court: any error would be harmless beyond a reasonable doubt given the overwhelming admissible evidence; conviction stands

Edwards v. Arizona, 451 U.S. 477 (1981) (police may not initiate interrogation after request for counsel)
Rhode Island v. Innis, 446 U.S. 291 (1980) (defines interrogation and the "functional equivalent" test)
McNeil v. Wisconsin, 501 U.S. 171 (1991) (limits on police-initiated interrogation after invocation)
Wyrick v. Fields, 459 U.S. 42 (1982) (suspect may initiate discussion and waive right to counsel)
Oregon v. Bradshaw, 462 U.S. 1039 (1983) (plurality) (distinguishes custodial inquiries from suspect-initiated requests)
Smith v. Illinois, 469 U.S. 91 (1984) (per curiam) (post-invocation waiver permissible if suspect initiates)
Arizona v. Fulminante, 499 U.S. 279 (1991) (confession reliability and harmless-error analysis)
Brecht v. Abrahamson, 507 U.S. 619 (1993) (standard for habeas harmless error)
Harrington v. Richter, 562 U.S. 86 (2011) (deference standard for §2254(d) unreasonable-application review)
Yarborough v. Alvarado, 541 U.S. 652 (2004) (general rules allow state-court leeway under AEDPA)
Dickerson v. United States, 530 U.S. 428 (2000) (Miranda as a constitutional rule)