Bobby v. Dixon: Does the denial of Miranda taint a later, proper confession?

Abstract

Archie Dixon, a murder suspect, claimed that the police violated his rights because they ignored his request for an attorney and by failing to Mirandize him when he was detained for forgery during a murder investigation. In a later relating to the investigation, Dixon was read his rights, and he confessed. Dixon was later sentenced to death, which was affirmed by the Ohio Appellate and the Supreme courts. However, the sentence was reversed by 6th Circuit Appeals Court. On Nov. 17th, the SCOTUS reversed the 6th Circuit in a per curium decision.

Dixon, a brutal murder suspect was interrogated at the police station on Nov. 4, 1993 that invoked the Fifth Amendment, his right of remaining silent in the absence of counsel (Ohio Ct. App. 1996). Prior to his second interrogation, the detectives refused to administer the Miranda warning since they feared that Dixon was to invoke his right to counsel if issued with Miranda warning and thus he will not meet the purpose of questioning. Dixon confessed to the murder charges after confessed to the forgery related charge several hours after being read his Miranda rights.