Facts of the case
Patrice Seibert was convicted of second degree murder for the death of 17 -year-old Donald Rector, who died in a fire set in the mobile home where he lived with Seibert. Several days after the fire, Seibert was interrogated by a police officer. The officer initially withheld her Miranda warnings, hoping to get a confession from her first. Once she had confessed, the officer took a short break from questioning, then read her her Miranda rights and resumed questioning her after she waived those rights. He prompted her to restate the confession that she had made earlier. Based on this second, Mirandized confession, Seibert was convicted.She appealed, charging that the officer’s intentional use of an un-Mirandized interrogation to get the initial confession made the later confession, though it occurred after she had waived her Miranda rights, inadmissable. The prosecution cited Oregon v. Elstad to argue that an initial, un-Mirandized confession did not make a defendant incapable of voluntarily waiving her Miranda rights and confessing later.The Supreme Court of Missouri agreed with Seibert, overturning the conviction.
Why is the case important?
Respondent, Seibert, brought appeal after she was convicted of second-degree murder based on a confession that was elicited after she had made an un-Mirandized confession.
When an officer intentionally decides to withhold Miranda warnings to elicit a confession, is a later-Mirandized confession admissible?
The second Post-Miranda confession is not admissible when a prior confession has been given unless the Miranda warning and accompanying break are sufficient to give the defendant the reasonable belief that she can decide not to speak with police.
The United States Supreme Court expressed the view that the accused’s post-warning statement was inadmissible at trial, because the officer’s midstream recitation of warnings after his initial interrogation and the accused’s unwarned confession could not effectively have complied with Miranda’s constitutional requirement, as the officer’s question-first tactic effectively had threatened to thwart Miranda’s purpose of reducing the risk that a coerced confession would be admitted. The Court held that the facts in the instant case did not reasonably support a conclusion that the warnings given could have served their purpose for when, as in the instant case, Miranda warnings were inserted in the midst of coordinated and continuing interrogation, the warnings were likely to mislead, and deprive an accused of knowledge essential to the accused’s ability to understand the nature of the accused’s rights, and the consequences of abandoning them. Furthermore, the Court held that it ordinarily would be unrealistic to treat two spates of integrated and proximately-conducted questioning as independent interrogations subject to independent evaluation simply because Miranda warnings had formally punctuated them in the middle.
- Advocates: Amy M. Bartholow argued the cause for Respondent Karen K. Mitchell argued the cause for Petitioner Irving L. Gornstein argued the cause for Petitioner, on behalf of the United States, as amicus curiae
- Petitioner: Missouri
- Respondent: Patrice Seibert
- DECIDED BY:Rehnquist Court
- Location: –
|Citation:||542 US 600 (2004)|
|Granted:||May 19, 2003|
|Argued:||Dec 9, 2003|
|Decided:||Jun 28, 2004|