Tuesday, November 5, 2013

Illinois v. Perkins case brief

Illinois v. Perkins case brief summary
496 U.S. 292 (1990)

Respondent prisoner made incriminating statements to an undercover agent while incarcerated. A district court granted the prisoner's motion to suppress the evidence because he had not been given Miranda warnings. The United States Court of Appeals for the Fifth Circuit affirmed the motion to suppress. Petitioner, the State of Illinois, was granted certiorari.

The prisoner claimed that the statements were properly excluded because he had not been given Miranda warnings by the undercover agent. The State alleged that the statements were voluntary and not coerced, and that Miranda warnings were not required when an undercover agent was asking questions that could elicit an incriminating response.


  • 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. 
  • 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. 
  • Miranda was not meant to protect suspects from boasting about their criminal activities.


The judgment of the appellate court affirming the grant of a motion to suppress was reversed.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

No comments:

Post a Comment

Exploring Career Paths: What Can You Do with a Juris Doctor Degree?

Earning a Juris Doctor (JD) degree is a significant accomplishment, opening a wide array of career paths beyond the traditional legal practi...