Jonathan Case

Paper 2

Facts

Jonathan, a disabled 12 year old boy passes away in his sleep due to his cerebral palsey. His mother, Patrice Seibert was afraid that she would be charged with neglect due to the bedsores that were on his body, so she sat down with her other two teenage sons and two of their friends and came up with a plan. The plan was to dispose of Jonathan's body by burning it in the mobile home they lived in. To make it look like Jonathan was not left unattended, they left Donald Rector, a mentally disabled teenager whom lived with them, in the mobile home as well. Donald died in the fire.

A week later Patrice was at a hospital, with one of her teenage sons that started the fire, when she was arrested, without being read her Miranda rights. Patrice was questioned and confessed. She was then given Miranda warnings and questioned again with this statement being recorded. Upon conclusion of the second interview, Patrice was charged with first-degree murder of Donald Rector.

History

Patrice Seibert was charged with first-degree murder of Donald Rector. Due to not being read her Miranda rights when she was first arrested and then only after she had already given one statement, Patrice wanted to exclude both prewarning and postwarning statements. During trial, the officer who questioned Patrice, stated that the information Patrice provided in her statement resembled the same information she provided prior to the Miranda warning. The trial allowed the second statement and suppressed the first statement, and the jury convicted Patrice of second-degree murder. The case was appealed to the Missouri Court of Appeals and the decision of the prior Court was affirmed. The Supreme Court of Missouri reversed the decision.

The Missouri Supreme Court held that the second statement was the product of the first statement and should have been suppressed. The Court also held that the postwarning confession was involuntary and therefore inadmissible.

Certiorari was granted to resolve a split in the Court of Appeals.

Issue

Is the second statement, given after the Miranda warning, admissible in Court?

Decision

The Supreme Court of the United States affirmed the decision. The Court concluded that because the recitation of the Miranda warnings after interrogation and unwarned confession in this case could not comply with Miranda's constitutional requirements, Patricia Seibert's postwarning statements are inadmissible.

Rationale

The Court viewed several cases upon making their decision.

Chavez v Martinez, 538U.S.760, 790(2003) - This Court in Miranda concluded that, "the accused must be adequately