Interrogation Without Questions: Rhode Island v. Innis and United States v. Henry

In Rhode Island v. Innis, the Court defined “interrogation” within the meaning of MirandaUnited States v. Henry, it defined “deliberate elicitation” within the meaning of Massiah. This article explores the implications of Innis and Henry, suggests readings of the new tests consistent with their purposes, and applies the tests to several situations where the scope of the fifth and sixth amendment protections remains unclear.