Facts
Jesse Gilbert was charged with armed robbery and the murder of a police officer. Gilbert would not answer questions about the robbery charge without a lawyer, but later answered questions about a robbery in which the robber, supposedly Gilbert, used a handwritten note demanding the money. He gave the police handwriting samples, which were later admitted into evidence. The police also had eyewitnesses identify Gilbert in a line-up that was conducted without notice to his attorney. During the trial, several witnesses identified Gilbert in the courtroom as being a part of several robberies; it could not be determined whether or not identifications in the court room were a result of the illegal line-ups that occurred before the trial. The