Patrice Seibert's twelve-year-old son Jonathan, who had cerebral palsy, died in his sleep.
Fearing charges of neglect because of bedsores on his body, Seibert was present when two of her teenage sons and two of their friends devised a plan to burn the family's mobile home with Donald Rector, a mentally ill teenager living with the family, inside to conceal the circumstances of Jonathan's death. Seibert's son Darian and a friend set the fire, resulting in Donald's death.
Five days later, police officers awakened Seibert at three o'clock in the morning at a hospital where Darian was being treated for burns. Officer Kevin Clinton arrested her without providing Miranda warnings, following instructions from Officer Richard Hanrahan. Seibert was taken to the police station, left alone in an interview room for fifteen to twenty minutes, and then questioned by Officer Hanrahan for thirty to forty minutes without Miranda warnings.
During the unwarned questioning, Officer Hanrahan squeezed Seibert's arm and repeatedly stated that Donald was also to die in his sleep, eventually obtaining her admission that she knew Donald was meant to die in the fire. After a twenty-minute coffee and cigarette break, Officer Hanrahan turned on a tape recorder, administered the Miranda warnings, obtained a signed waiver, and resumed questioning by referencing the prior discussion and confronting Seibert with her prewarning statements. Seibert reaffirmed the details of the plan, including that Donald was supposed to die in his sleep.
At the suppression hearing, Officer Hanrahan testified that he made a conscious decision to withhold Miranda warnings, question first, give the warnings, and then repeat the question until obtaining the answer previously given. He acknowledged that Seibert's ultimate statement was largely a repeat of information obtained prior to the warning. The trial court suppressed the prewarning statement but admitted the postwarning responses, leading to Seibert's conviction for second-degree murder by a jury. The Missouri Court of Appeals affirmed the conviction. The Missouri Supreme Court reversed. The United States Supreme Court granted certiorari to resolve a split in the courts of appeals.
View case