Illinois v. Perkins Case Brief

Why is the case important?

An undercover police agent was placed in jail with the suspect and got them to elicit incriminating statements.

Facts of the case

While being held in jail, Perkins freely confessed to committing a murder to an undercover police officer who was posing as another inmate.

Question

Are Miranda warnings required when an undercover agent is asking questions that could elicit an incriminating result?

Answer

No. Reverse the appellate court’s decision affirming the suppression of the statements.
The Fifth Amendment privilege versus self-incrimination is not implicated when a suspect is not aware they are speaking to law enforcement, and then gives incriminating statements, thus admit the statements into evidence.

Conclusion

On certiorari, the United States Supreme Court reversed and remanded. The Court held that Miranda warnings were not required when the suspect was unaware that he was speaking to a law enforcement officer and gave a voluntary statement. The Court found that conversations between suspects and undercover agents did not implicate the concerns underlying Miranda. According to the Court, the essential ingredients of a police-dominated atmosphere and compulsion were not present when an incarcerated person spoke freely to someone he believed to be a fellow inmate. Coercion was to be determined from the perspective of the suspect. Ploys to mislead a suspect or lull him into a false sense of security that did not rise to the level of compulsion or coercion to speak were not within the concerns of Miranda warnings. The Court averred that Miranda was not meant to protect suspects from boasting about their criminal activities.

  • Case Brief: 1990
  • Petitioner: Illinois
  • Respondent: Perkins
  • Decided by: Rehnquist Court

Citation: 496 US 292 (1990)
Argued: Feb 20, 1990
Decided: Jun 4, 1990