Seibert vs. Missouri
Devanney, Joe, Devanney, Diane, Law & Order
Since its inception in 1966, the famous Miranda rule governing police interrogations has bedeviled courts, police officers, prosecutors, and defense lawyers. Although the core of the Miranda ruling-that police may not question a suspect unless he has been warned of his right to silence and counsel-is clear, applying it in the uncertain and ever changing world of day-to-day police work has been difficult.
In June 2004, the United States Supreme Court, by a five to four vote in the case of Seibert vs. Missouri, ruled on one of the major Miranda issues that had been unresolved. Specifically, the court, in a ruling that favored the defense, determined that police interrogation techniques that were designed to get incriminating statements out of suspects after deliberately delaying Miranda warnings was unconstitutional.
The facts of the case began when Patrice Seibert was arrested for murder and arson following the death of Donald Rector, an 18-year-old mentally ill youth, in a fire in her mobile home. As it was subsequently determined, Seibert set the fire to cover up the natural death of her 12-year old son, Jonathan, who had cerebral palsy. It was her fear that she would be charged with neglect in Jonathan's death. The death of Rector was planned to make it look as though Jonathan had an attendant when he died.
A few days after the fire, police questioned Siebert. She was deliberately not given Miranda warnings, but instead questioned for about 30 to 40 minutes. She then admitted Rector was meant to die in the fire. After a 20-minute break, she was read the Miranda warnings, executed a waiver of them in writing and then requestioned. Seibert, not surprisingly, then gave essentially the same incriminating statements as earlier.
Nobody ever disputed that the first set of responses by Seibert was inadmissible. However, at the suppression hearing at the trial level, the officer who interrogated her testified that the decision to initially withhold the warnings was deliberate and designed, once the information had been extracted, to only then give the Miranda warnings and follow them with questions meant to duplicate the first set of responses.
Seibert was convicted of firstdegree murder and appealed. The Missouri Supreme Court reversed her conviction and the state appealed to the United States Supreme Court.
At the heart of the state's argument about the legality of this interrogation technique was the 1985 United States Supreme Court case of Oregon vs. Elstad, where it was held that a second incriminating statement was admissible, after Miranda warnings had been given, even though an initial (and inadmissible) statement was taken without the warnings.
At first glance, the Elstad ruling seemed to be right on point with the facts in Siebert. However, the Supreme Court viewed the two cases as vastly different. According to Justice Souter, who (joined by Justices Stevens, Breyer, and Ginsberg) authored the Seibert decision, the facts in Elstad involved a defendant who gave an incriminating statement as he was arrested at his home, then taken to a police station, given the Miranda warnings, and finally questioned again. The facts in Elstad, according to Justice Souter, did not involve deliberate manipulations by the police. …