Repository Collection 03

Missouri v. Seibert

CASE ENTRY

Last Revised • July 9, 2026

This Source Verification Page documents the United States Supreme Court's decision in Missouri v. Seibert, cited in Claim I of the Supplemental Motion. The decision established the constitutional rule governing deliberate "question first, warn later" interrogation strategies and explains when post-Miranda statements must be excluded because earlier unwarned questioning rendered subsequent Miranda warnings ineffective.


Related SMAR Citation

“[Missouri v. Seibert, 542 U.S. 600, at 2605 (2006)]”
“[At 2611]”


Case Name

Missouri v. Seibert


Citation

542 U.S. 600 (2004)


Date

June 28, 2004


Verification Source

United States v. Mashburn, 406 F.3d 303 (4th Cir. 2005)


Source Location

Supreme Court of the United States


Highlighted Pages

2 - 3, 6 - 8


Referenced in the Supplemental Motion

Page 41 - 42, Paragraph: 80 - 81


Source Status

✔ Original Court Order obtained and reviewed.

✔ Relevant passages highlighted.

✔ Publicly available source

✔ Included within the Source Verification Archive


Cited to Support

Paragraph 80:
May's reliance upon Missouri v. Seibert, 542 U.S. 600 (2004), for the legal principle that Miranda warnings administered after an initial unwarned custodial interrogation may be ineffective when law enforcement deliberately employs a question-first, warn-later interrogation strategy. Seibert is cited to establish that postwarning statements obtained through such a strategy may be inadmissible unless sufficient curative measures are taken before the subsequent questioning. May relies upon this authority to support his claim that APD officers questioned him while in custody prior to administering Miranda warnings and that no curative measures were taken before Detective Romick obtained his subsequent statements.

Paragraph 81:
May's reliance upon Missouri v. Seibert, 542 U.S. 600 (2004), for the principle that closely connected rounds of questioning conducted before and after Miranda warnings should not automatically be treated as separate interrogations merely because warnings were administered between them. The cited passage is relied upon to establish the Supreme Court's recognition that integrated and continuous questioning may constitute a single interrogation for constitutional purposes. May relies upon this authority to support his claim that Detective Romick's post-warning interrogation was a continuation of the earlier questioning conducted by Officer Moore and other law enforcement personnel rather than a separate and independent interview.


Supporting Documents

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Working research copy containing the highlighted passages cited in the Supplemental Motion.

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