In the case of Arizona v. Roberson, the U.S. Supreme Court ruled in 1987 that once a suspect invokes his right to counsel during an interrogation about one crime, law enforcement cannot later question him about any other crimes without his attorney present. The decision was based on the Fifth Amendment's protection against self-incrimination and Sixth Amendment's guarantee of legal representation. The ruling stemmed from an incident involving Lloyd Eldon Roberson Jr., who had been arrested for burglary and invoked his right to counsel during questioning by police officers in Tucson, Arizona. Later, while still in custody but without a lawyer present, he was questioned again by another officer regarding a different burglary case which led to incriminating statements being made by Mr.Roberson.

In the dissenting opinion for Arizona v. Roberson, Justice White argued that the majority's decision was not supported by precedent and unnecessarily expanded Miranda rights in a way that could hinder effective law enforcement. He contended that previous rulings had established an exception to Miranda when public safety is at risk, which he believed applied in this case where police were investigating a serious crime. Furthermore, he disagreed with the majority's interpretation of Edwards v. Arizona as requiring counsel to be present during all questioning after invocation of right to counsel; instead, he saw it as only prohibiting further interrogation on matters already discussed without counsel present. He also criticized the ruling for failing to consider practical implications such as potential difficulties in communicating between different officers or departments about whether a suspect has invoked their rights.