In Duckworth v. Eagan (1988), the US Supreme Court ruled that a Miranda warning, which informs suspects of their rights during arrest and interrogation, does not need to follow an exact format as long as it communicates the essential information. The case involved William Eagan who was convicted for attempted murder in Indiana state court. He appealed his conviction arguing that he had not been properly read his Miranda rights because the police officer told him legal counsel would be appointed "if and when you go to court". The Supreme Court upheld Eagan's conviction by a 6-3 vote stating that while this wording differed from standard language, it did adequately convey the right to have an attorney present before questioning begins or at any point during questioning. This ruling affirmed law enforcement’s ability to paraphrase these warnings without invalidating them so long as they accurately conveyed suspects' constitutional protections against self-incrimination.

In the dissenting opinion for Duckworth v. Eagan, Justice Thurgood Marshall argued that the majority's decision undermined the Miranda rule and its purpose of protecting suspects from police coercion during interrogations. He contended that a warning which suggests to an accused person that they may only consult with an attorney if one is physically present does not adequately convey their rights as required by Miranda. Furthermore, he disagreed with the majority's view on how courts should evaluate whether warnings are constitutionally adequate; instead of considering them in isolation, he believed they should be evaluated in context to ensure they truly inform suspects about their rights. In this case, he felt it was misleading and confusing for police officers to tell Kevin Eagan his right to counsel would be honored "when and if" his interrogation moved into court proceedings.