Interrogations and confessions

Question 1

Rhode Island v. Innis

Answer 1

Facts
On January 12, 1975, John Mulvaney, a taxi driver, was murdered in Providence, Rhode Island. Five days later, another taxi driver, Gerald Aubin, reported being robbed by a man with a sawed-off shotgun, later identified as the respondent. The Providence police arrested the respondent early on January 17, 1975. After his arrest, the respondent was informed of his Miranda rights multiple times and requested a lawyer. While being transported to the police station in a police car, three officers, instructed not to question or coerce the respondent, conversed among themselves about the danger a missing shotgun could pose to nearby handicapped children. Overhearing this, the respondent volunteered to show the officers where the gun was hidden. Subsequently, the respondent was charged with kidnapping, robbery, and murder. At trial, the court admitted the shotgun and statements regarding its discovery, leading to the respondent’s conviction. The Rhode Island Supreme Court, however, reversed the conviction, finding that the respondent had been “interrogated” in violation of Miranda rights, as the officers’ conversation constituted “subtle coercion.”

Issue
The central issue was whether the respondent was “interrogated” in violation of Miranda v. Arizona when the police officers conversed among themselves about the danger posed by the missing shotgun, leading the respondent to volunteer information about its location, even though he had requested an attorney and had been advised of his Miranda rights.

Holding
The U.S. Supreme Court held that the respondent was not “interrogated” within the meaning of Miranda v. Arizona when he volunteered information about the shotgun’s location in response to police officers’ conversation. Therefore, the actions of the police did not violate the respondent’s Miranda rights.

Question 2

Illinois v. Perkins

Answer 2

Facts
In November 1984, Richard Stephenson was murdered in East St. Louis, Illinois. The case remained unsolved until March 1986, when one Donald Charlton, an inmate at the Graham Correctional Facility, informed police that Lloyd Perkins, the respondent, had detailed his involvement in the murder while they were both incarcerated. Perkins had been released but was later found in jail in Montgomery County on unrelated charges. To further investigate, an undercover agent, John Parisi (using the alias “Vito Bianco”), was placed in the cellblock with Perkins without giving him Miranda warnings. Perkins disclosed details of the Stephenson murder to Parisi, believing him to be a fellow inmate. The trial court suppressed these statements, and the appellate court affirmed, citing the requirement of Miranda warnings for incarcerated suspects.

Issue
The core issue was whether an undercover law enforcement officer must provide Miranda warnings to an incarcerated suspect before asking questions that might elicit an incriminating response, especially when the suspect is unaware that they are speaking to a government agent.

Holding
The Supreme Court reversed the appellate court’s decision, holding that Miranda warnings are not required when the suspect is unaware that he is speaking to a law enforcement officer and gives a voluntary statement. Therefore, the statements made by Perkins to the undercover agent were admissible.