Despite the Burger Court\u27s history of judicial conservatism, the Supreme Court in United States v. Henry exceeds the liberality of the Warren Court in the area of criminal defendant rights. The decision in Henry clearly provides further limitations upon the government\u27s ability to conduct interrogations. The author examines the Court\u27s factual and legal analysis of the case, emphasizes how the test established in Henry surpasses the rule promulgated in Massiah, and discusses the decision\u27s impact as well as the curious turnabout of Chief Justice Burger
