Laying Out Evidence Wasn’t Two-Part Seibert Tactic

March 2, 2011, 5:00 AM UTC

Police officers did not engage in the type of unwarned questioning condemned in Missouri v. Seibert, 542 U.S. 600, 75 CrL 286 (2004), when they confronted a suspect with his confederates’ confessions before giving him the warnings required by Miranda v. Arizona, 384 U.S. 436 (1966), the U.S. Court of Appeals for the Seventh Circuit held Feb. 14. (United States v. Vallar)

In Seibert, the U.S. Supreme Court addressed a “question first, warn later” tactic in which officers first question a suspect without providing the Miranda warnings and, once the suspect incriminates himself, they provide ...

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