The “Buried Bodies” Case: If A Killer Confesses To His Lawyers, What Must They Do? A Study In Legal Ethics

The 1974 murder trial of Robert Garrow in the death of Philip Domblewski raised a key question that has been debated in legal-ethics classes ever since: If a murder suspect tells his attorneys where the bodies are buried, are the attorneys obligated to report that information to the court?

As Garrow’s trial began, he admitted to killing Domblewski to his defense team, Frank Armani and Francis Belge. He also confessed to murdering two women, Alicia Hauck and Susan Petz, who had been camping when he came across them in the woods.

Garrow gave his lawyers specific enough details on where the women’s bodies were buried that Belge and Armani were able to go to the scene and locate both corpses.

Belge reportedly discovered Susan Petz’s body in a mineshaft and took photos. Her skull had been resting a few feet away, and Belge moved it back to the corpse. Next, Armani and Belge together came across Alicia Hauck’s remains among brush near a cemetery.

Considering that Armani reportedly knew Hauck’s father from his work at the courthouse, and that Armani’s daughter was a high school classmate of hers, what the two lawyers did next could not have been easy.

Frank Armani [screenshot]

Frank Armani [screenshot]

Even in the face of emotional outpourings, the two men held to the lawyer’s oath to protect and preserve the confidence of their client. They told no one of what they had discovered. Even when Petz’s family drove from their Illinois home to talk with Armani just on hearing speculation that Garrow might have been linked to Petz’s disappearance, Armani held to his oath.

Armani and Belge met with the prosecution and tried to negotiate a plea bargain using information about two unsolved murders, but it didn’t work. As an avenue of last resort, they advised Garrow to plead insanity.

After initially stating that Garrow would not testify, Belge called him to the stand — without consulting Armani. While under oath, Garrow admitted to killing Petz and Hauck in addition to Domblewski. Armani exploded in anger, and the attorneys collapsed into a fistfight on the floor of the court.

The jury convicted Garrow for Domblewski’s murder. A judge sentenced him to life in prison with a minimum of 35 years.

After the trial, in June 1974, Armani and Belge revealed at a press conference that they did, in fact, know about the two girls and their final resting places. Community outrage was instant and intense, leading to death threats and prompting the attorneys to relocate their families for safety reasons.

A death threat that Armani received on a napkin [screenshot]

A death threat that Armani received on a napkin [screenshot]

At the time, public esteem for lawyers had already hit a low point in the wake of the Watergate hearings. It was in that atmosphere that a grand jury convened to decide whether Armani and Belge should be charged for not reporting the information. The court indicted Belge, but let Armani off the hook.

As Belge went to trial, law schools across the country were just beginning to draft material for legal-ethics classes. This case gave students and professors plenty to work with.

In his defense, Armani likened his situation to the sanctity of the confessional, reasoning that lawyers have the same obligation that a priest does upon hearing the secrets of a parishioner. A jury agreed, and exonerated Belge for keeping his client’s confidence.

This vintage video includes interviews with some who were involved in the aftermath of the case:

The entire affair, which would come to be known as the “Lake Pleasant Bodies Case” or the “Buried Bodies Case,” stands as one of the crucial building blocks in establishing the often volatile study of legal ethics. It raised questions that can — and must — be profoundly considered and actively debated. Among them:

• What should an attorney do if their own personal moral code comes into conflict with their oath to protect a client’s confidence?

• Is Armani’s analogy correct — is attorney-client confidentiality is just as sacrosanct the confidence of the confessional?

• If a lawyer gives up information once, could future clients ever trust them to keep confidence?

We want to know what you think. How would you have resolved this ethical and moral dilemma? Tell us in the comments section.

Read more:
New York Times archive
American Bar Association
Law Times

Main photo: Robert Garrow Wanted Poster [New York State Police]


  • Deb

    The majority of lawyers are POS’s.

  • Bhavesh Patel

    Misplaced Blame Here…

    Why is everyone blaming Frank Armani when it’s clear that he was conflicted to uphold the best Judicial System in the world, despite its imperfections.

    The REAL ethically compromised person here is the DA. Read it again. This DA had a chance to find the bodies and still put the murderer away from harming the public again. What is his reasoning for not doing so? Political Capital

    So Politics was more important to the DA than the pain and suffering of the parents. That’s the real take home message.

    We have a judicial system that we will continuously modify, but Mr. Armani at great emotional burden, financial burden, and physical burden made the hard, ethical choice as the law is written today. For people who are not in a profession and don’t take an oath, it’s easy for you to blame someone for making the choice that you disagree with.

    Again, why didn’t the DA just take the plea bargain? Children would have been found right away, pain and suffering would have been alleviated by the parents, the murderer would have been put away for life. It didn’t happen because the DA cared too much about his reputation. He’s the real ethically compromised character in this story.