Texas v. Cobb

In 1994, while under arrest for an unrelated offense, Raymond Levi Cobb confessed to a home burglary. Cobb, however, denied knowledge of the disappearance of a woman and child from the home. In 1995, after counsel was appointed to represent him in the burglary case, Cobb confessed to killing the woman and child to his father, who contacted the police. Cobb, now in custody, waived his rights under Miranda and confessed to the murders. Cobb was then indicted, convicted, and sentenced to death. On appeal to the Texas Court of Criminal Appeals, Cobb argued that his confession should have been suppressed because it was obtained in violation of his Sixth Amendment right to counsel, which he claimed attached when counsel was appointed in the burglary case. In reversing, the court held that once the right to counsel attaches to the offense charged, it also attaches to any other offense that is very closely factually related to the offense charged.