Missouri v. Seibert

Missouri v. Seibert Case Brief

United States Supreme Court
542 U.S. 600 (2004)

ISSUE: Did midstream Miranda warnings serve to sufficiently dissipate the taint of previous, unwarned questions and answers if the two sessions of questioning were essentially continuous?
HOLDING: No.
FACTS:
  • Seibert's 12-year-old son died of cerebral palsy, and she devised a plan with 2 of her sons and 2 of their friends to burn their mobile home with another boy in it to cover it up
  • One of the sons set the mobile home afire, and the boy inside died
  • Police then arrested D in the hospital 5 days later, and the arresting officer was told not to Mirandize D
  • At the station, D was questioned to 30-40 minutes without Miranda warnings while an officer squeezed her arm and told her that "Donald was also to die in his sleep"
  • D was then given a 20-minute coffee break, was Mirandized, and signed a waiver form
  • Subsequent questioning explicitly referred to the 1st round of unwarned questioning and was largely a repeat of the info that was obtained prior to warning
PROCEDURAL HISTORY:
  • Trial Ct. suppressed pre-warning statements but refused to suppress post-warning statements
  • Ct. App. affirmed; Sup. Ct. reversed
REASONING:
  • Warnings designed to be ineffective: It is likely that if the interrogators employ the technique of withholding warnings until after interrogation succeeds in eliciting a confession, the warnings will be ineffective in preparing the suspect for successive interrogation, close in time and similar in content
    • A suspect would hardly think he has a genuine right to remain silent
    • Such warnings are likely to mislead and deprive a D of knowledge essential to his ability to understand the nature of his rights and consequences of abandoning them
  • Factors: Series of relevant factors to consider in determining whether Miranda warnings delivered midstream could be effective enough to accomplish their object:
    • Completeness & detail of the questions and answers in the 1st round of interrogation
    • Overlapping content of the 2 statements
    • Timing and setting of the 1st and 2nd
    • Continuity of police personnel
    • Degree to which the interrogator's questions treated the 2nd round as continuous with the 1st
  • Strategy here to undermine Miranda: Facts here reveal a police strategy adopted to undermine Mirandawarnings
    • Reasonable to regard the 2 sessions as parts of a continuum in which it would have been unnatural to refuse to repeat at the 2nd stage what had been said before
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