Massiah v. United States
E237789
Massiah v. United States is a landmark 1964 U.S. Supreme Court case that held the government violates the Sixth Amendment right to counsel when it deliberately elicits incriminating statements from an indicted defendant in the absence of their attorney.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Massiah v. United States canonical | 3 |
How this entity was disambiguated
This entity first appeared as the object of triple T2128644 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Massiah v. United States Context triple: [Escobedo v. Illinois, relatedCase, Massiah v. United States]
-
A.
Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
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B.
Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
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C.
Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
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D.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
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E.
Dickerson v. United States
Dickerson v. United States is a 2000 U.S. Supreme Court case that reaffirmed the constitutional basis of Miranda warnings and held that Congress could not overrule Miranda v. Arizona by statute.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Massiah v. United States Target entity description: Massiah v. United States is a landmark 1964 U.S. Supreme Court case that held the government violates the Sixth Amendment right to counsel when it deliberately elicits incriminating statements from an indicted defendant in the absence of their attorney.
-
A.
Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
-
B.
Abrams v. United States
Abrams v. United States was a 1919 U.S. Supreme Court case that upheld the conviction of antiwar activists under federal law and is best known for Justice Holmes’s famous dissent articulating the “marketplace of ideas” concept in free speech jurisprudence.
-
C.
Dennis v. United States
Dennis v. United States is a landmark 1951 U.S. Supreme Court decision that upheld the convictions of Communist Party leaders under the Smith Act, significantly shaping First Amendment jurisprudence on speech advocating the overthrow of the government.
-
D.
Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
-
E.
Dickerson v. United States
Dickerson v. United States is a 2000 U.S. Supreme Court case that reaffirmed the constitutional basis of Miranda warnings and held that Congress could not overrule Miranda v. Arizona by statute.
- F. None of above. chosen
Statements (48)
| Predicate | Object |
|---|---|
| instanceOf |
Sixth Amendment case
ⓘ
United States Supreme Court case ⓘ landmark criminal procedure case ⓘ |
| amendmentInvolved |
U.S. Constitution, Sixth Amendment
ⓘ
surface form:
Sixth Amendment
|
| appliesTo |
post-indictment interrogation
ⓘ
use of undercover informants after indictment ⓘ |
| appliesWhen | adversary judicial proceedings have been initiated ⓘ |
| arguedDate | 1963-12-12 ⓘ |
| citation | 377 U.S. 201 ⓘ |
| constitutionalProvisionInterpreted |
U.S. Constitution, Sixth Amendment
ⓘ
surface form:
Sixth Amendment to the United States Constitution
|
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1964-05-18 ⓘ |
| dissentBy |
Byron R. White
ⓘ
surface form:
Justice Byron White
John M. Harlan II ⓘ
surface form:
Justice John M. Harlan II
Tom C. Clark ⓘ
surface form:
Justice Tom C. Clark
|
| distinguishedFrom | Fifth Amendment Miranda right to counsel ⓘ |
| docketNumber | 199 ⓘ |
| excludesFromEvidence | incriminating statements deliberately elicited after indictment without counsel ⓘ |
| factPattern | Government used a co-defendant cooperating with federal agents to record conversations with Massiah after indictment and release on bail ⓘ |
| fullName | Massiah v. United States self-link ⓘ |
| holdingCharacterization | landmark decision expanding protections for the right to counsel ⓘ |
| issue | Whether incriminating statements deliberately elicited from an indicted defendant in the absence of counsel are admissible at trial ⓘ |
| joinedByInMajority |
Earl Warren
ⓘ
surface form:
Chief Justice Earl Warren
Justice Arthur Goldberg ⓘ Hugo L. Black ⓘ
surface form:
Justice Hugo Black
William J. Brennan Jr. ⓘ
surface form:
Justice William J. Brennan Jr.
William O. Douglas ⓘ
surface form:
Justice William O. Douglas
|
| jurisdiction | federal criminal prosecutions ⓘ |
| languageOfProceeding | English ⓘ |
| legalHolding | The government violates the Sixth Amendment right to counsel when it deliberately elicits incriminating statements from an indicted defendant in the absence of counsel ⓘ |
| legalPrinciple | Once formal criminal proceedings have begun, the government may not deliberately elicit statements from the defendant without counsel present or a valid waiver ⓘ |
| majorityOpinionBy |
Potter Stewart
ⓘ
surface form:
Justice Potter Stewart
|
| page | 201 ⓘ |
| petitioner | Winston Massiah ⓘ |
| prohibits | deliberate elicitation of incriminating statements from an indicted defendant without counsel ⓘ |
| relatedDoctrine | Massiah doctrine ⓘ |
| relatedTo |
Brewer v. Williams
ⓘ
Escobedo v. Illinois ⓘ Maine v. Moulton ⓘ Miranda v. Arizona ⓘ United States v. Henry ⓘ |
| reporter | United States Reports ⓘ |
| respondent |
United States of America
ⓘ
surface form:
United States
|
| result | Conviction reversed ⓘ |
| rightInvolved | right to counsel ⓘ |
| subjectMatter | use of surreptitious government agents to obtain statements ⓘ |
| volume | 377 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Massiah v. United States Description of subject: Massiah v. United States is a landmark 1964 U.S. Supreme Court case that held the government violates the Sixth Amendment right to counsel when it deliberately elicits incriminating statements from an indicted defendant in the absence of their attorney.
Referenced by (3)
Full triples — surface form annotated when it differs from this entity's canonical label.