Missouri v. Seibert

542 U.S. 600 (2004)

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Nature of the Case

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Facts

D's 12-year-old son, Jonathan, had cerebral palsy. The boy died in his sleep. D feared charges of neglect because of bedsores on his body. Two of her teenage sons and two of their friends devised a plan to conceal the facts surrounding Jonathan's death by incinerating his body in the course of burning the family's mobile home. They planned to leave Donald Rector, a mentally ill teenager living with the family, to avoid any appearance that Jonathan had been unattended. D's son Darian and a friend set the fire, and Donald died. D was arrested, and police were under orders not to give her a Miranda warning. D confessed. D was then given a Miranda warning, and immediately the interrogation began again with full reference to the previous confession. D confessed again in a matter of minutes. D sought to exclude both statements. The police admitted they made a 'conscious decision' to withhold Miranda warnings: question first, then give the warnings, and then repeat the question 'until I get the answer that she's already provided once.' The court admitted the responses given after the Miranda recitation. D was convicted of second-degree murder. The Court of Appeals affirmed. The State Supreme Court reversed holding that '[i]n the circumstances here, where the interrogation was nearly continuous, ... the second statement, clearly, the product of the invalid first statement should have been suppressed.' The Supreme Court granted certiorari.