Bobby v. Dixon

The Court distinguished this case from Missouri v. Seibert in that it did not find the “two-step interrogation technique” used in that case. “In Seibert, the suspect’s first, unwarned interrogation left ‘little, if anything, of incriminating potential left unsaid,’ making it ‘unnatural’ not to ‘repeat at the second stage what had been said before (quoting Seibert).’” In this instance, there was no confession to repeat after being provided Miranda warnings. “Four hours passed between [the defendant’s] unwarned interrogation and his receipt of Miranda rights, during which time he traveled from the police station to a separate jail and back again; claimed to have spoken to his lawyer; and learned that police were talking to his accomplice and had found [the victim’s] body. Things had changed.” As the Court found no nexus between the defendant’s “unwarned admission to forgery and his later, warned confession to murder” the confession was voluntarily obtained.