Missouri vs. Seibert
The petitioner was a woman named Seibert. She was charged and convicted of second-degree murder for her alleged involvement in the death of a 17-year-old handicapped boy. Seibert son who had died earlier and to conceal evidence of parental negligence, she colluded with her other son to set her house of fire. She realized that if only her son’s body was found in the charred house, this would also suggest neglectful parenting and so, a decision was made to leave the 17 years old boy in the house too. The police became suspicious of her involvement and picked her up to question her. The lead interrogating officer did not at first read Seibert her Miranda rights because he had been trained that when criminal suspects are questioned first, they are likely to confess to the accused crimes again once their rights are actually read to them. Ms Seibert confessed to her involvement in the crime. The officer then took a break and when he came back, he read her the Miranda rights and resumed questioning. He prompted Seibert to restate her confession as she had confessed earlier. This second question was used as testimony to provide evidence in court, and Seibert was consequently convicted. Seibert later appealed at the Missouri Supreme Court. She argued that the interrogating officer’s purposeful questioning prior to reading her the Miranda rights had poisoned the admissibility of her second confession.
The issue raised by this case was whether an officer’s intentional questioning of a suspect before reciting the Miranda rights to him/her undermines the protection that the Fifth Amendment offers to suspects and that renders the following testimony inadmissible?.
The court ruled that the confession was indeed inadmissible because it violated the Fifth Amendment. It was obtained prior to the suspect being made aware of her Miranda rights
The reasoning and holding for the decision was that: Statements repeated after an officer gives the Miranda warning midway through a questioning session violate the Fifth Amendment. The Miranda rights were developed free and rational choice about testifying. The use of the two-step interrogation in this case was, therefore, a violation of the Miranda.
The ruling of this court further reinforced the importance of following the complete rule of law when questioning suspects or conducting criminal investigations.
USA vs. Patane
The petitioner, Samuel Patane, was arrested for menacing and harassing his former girlfriend. He was later released on bail but was handed a restraining order forbidding him from contacting his girlfriend. He, however, violated the restraining order and contacted his former girlfriend who reported to the police and informed them that he possessed a handgun. Police officer proceeded to his house where the arresting officer started to read him the Miranda rights. Patane, however, interrupted the officer and stated that he understood his Miranda rights. The officer, therefore, did not complete reading out the rights. The officer then questioned Patane about the gun. He admitted that he was indeed in possession of the firearm and told the officer where it was hidden. The officer confiscated the weapon. In the court, Patane was convicted of violating his restraining order and possessing a firearm in spite of the fact that he was a felon. During the trial, Patane argued that his arrest essentially violated both the Fourth and the Fifth Amendments. This was because probable of the absence of a probable cause of arrest and because the gun was seized after an un-Mirandized confession.
The legal question in this case was whether evidence or testimony realized found after a confession that is un-Mirandized is admissible in court
The district court ruled that the gun was indeed inadmissible as evidence. The court’s reasoning was that unwarned statements are essentially a violation of a suspect’s constitutional rights. By not fully reading out the Miranda rights to the suspect, the officer rendered any testimony or confession realized after that as inadmissible in court.
Just like the Seibert and the Missouri case, the ruling further reinforced the importance of reading the full Miranda rights to a suspect. These rights should be read to any suspect to make sure that he is completely aware of the consequences of his statements and the fact that they may be used to convict him in court.
Works Cited
"Cases - 2013 term | The Oyez Project at IIT Chicago-Kent College of Law." The Oyez Project at IIT Chicago-Kent College of Law | A Multimedia Archive of the Supreme Court of the United States. N.p., n.d. Web. 27 Jan. 2014.
