Missouri v. Seibert

After her son Jonathan died of natural causes but with untreated bed sores, Patrice Seibert (defendant) — fearing a child-abuse charge — arranged to burn down the family's trailer with his body inside, leaving mentally ill teenager Donald Rector inside as well so it wouldn't look like Jonathan had been unattended; Donald died in the resulting fire. Police deliberately questioned Seibert without Miranda warnings and obtained a confession that she left Donald in the trailer, then gave her the warnings about 20 minutes later, had her waive them, reminded her of her earlier confession, and obtained a second, formally warned confession. The trial court suppressed only the first confession, a jury convicted Seibert of second-degree murder, and after her conviction was affirmed on direct appeal, the Missouri Supreme Court held the second confession violated Miranda and should be suppressed; the state successfully petitioned the U.S. Supreme Court.