Monday, November 4, 2013

Missouri v. Seibert case brief

Missouri v. Seibert case brief summary
542 U.S. 600 (2004)

A jury convicted defendant of second-degree murder in a state trial court. On appeal, the state court of appeals affirmed. The Supreme Court of Missouri reversed. The United States Supreme Court granted certiorari to resolve a split in the United States Courts of Appeals.

After defendant's bedridden son's death, a mentally ill teenager died during a scheme to conceal defendant's neglect of the son. Employing a procedure called "question-first" interrogation, police arrested defendant for the death of the teenager but refrained from giving her Miranda warnings. Twenty minutes after eliciting a confession, police Mirandized defendant and requestioned her. The trial court suppressed the prewarning statement but admitted the postwarning recitation. The Missouri Supreme Court found that, because the interrogation was nearly continuous, the second statement, clearly the product of the invalid first statement, also should have been suppressed.

  • The United States Supreme Court held that the question-first tactic effectively threatened to thwart Miranda's purpose of reducing the risk that a coerced confession would be admitted. 
  • Because the facts did not reasonably support a conclusion that the warnings given could have served their purpose, the post-warning statements also were inadmissible. 
  • Strategists dedicated to draining the substance out of Miranda could not accomplish by training what the Court had previously held Congress could not do by statute.


The Court affirmed the judgment of the Missouri Supreme Court.

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

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