Patrice Seibert's 12-year-old son, Jonathan, had cerebral palsy. When Jonathan died in his sleep, Seibert feared charges of neglect because there were bedsores on his body. In Seibert's presence, two of her teenage sons and two of their friends devised a plan to conceal the facts surrounding Jonathan's death by incinerating his body in the course of burning the family's mobile home. Under the plan, the fire would be set while Donald Rector, a mentally ill teenager who lived with the family, was asleep in the mobile home.
The fire and the presence of Rector's body would eliminate any indication that Jonathan had been the victim of neglect. Seibert's son Darian and a friend set the fire as planned, and Rector died. Five days later, police officers awakened Seibert at 3:00 a.m. at a hospital where Darian was being treated for burns. An officer arrested Seibert but, in accordance with instructions from Officer Hanrahan, refrained from giving Miranda warnings at the time of the arrest. After Seibert had been taken to the police station and left alone in an interview room for 15 minutes, Hanrahan questioned her for 30 to 40 minutes without giving Miranda warnings. During this questioning, Hanrahan squeezed Seibert's arm and repeated this statement: "Donald [Rector] was also to die in his sleep." When Seibert finally admitted that she knew Rector was meant to die in the fire, she was given a 20-minute coffee and cigarette break. Hanrahan then turned on a tape recorder, gave Seibert the Miranda warnings, and obtained a signed waiver of rights from her. He resumed the questioning with "OK, Patrice, we've been talking for a little while about what happened on Wednesday, the twelfth, haven't we?" Hanrahan then confronted Seibert with her pre-Miranda -warnings statements about the plan to set the fire and the understanding that Rector would be left sleeping in the mobile home. Specifically, Hanrahan referred to Seibert's pre- Miranda -warnings statements by asking, in regard to Rector, "[Didn't you tell me he was supposed to die in his sleep?" and "So he was supposed to die in his sleep?" Seibert answered "Yes" to the second of these post-warnings questions. After being charged with murder for her role in Rector's death, Seibert sought to have her pre-Miranda-warnings statements and her post- Miranda -warnings statements suppressed (i.e., excluded from evidence) as the remedy for supposed Fifth Amendment and Miranda violations. At the hearing on Seibert's suppression motion, Hanrahan testified that he decided to withhold Miranda warnings and to resort to an interrogation technique he had been taught: question first, then give the Miranda warnings, and then repeat the question "until I get the answer that she's already provided once." Hanrahan acknowledged that Seibert's ultimate statement was "largely a repeat" of information obtained prior to the giving of the Miranda warnings. The Missouri trial court suppressed Seibert's pre- Miranda -warnings statements but permitted use of her post-warnings statements. A jury convicted Seibert, and the Missouri Court of Appeals affirmed.
However, the Missouri Supreme Court reversed, holding that Seibert's post-warnings statements should have been suppressed as well. The U.S. Supreme Court agreed to decide the case at the request of the state of Missouri. How did the Supreme Court rule on the suppression issue?

  • CreatedJuly 16, 2014
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