Transcription
Little did Lloyd Perkins know that the supposed fellow inmate to whom he bragged about committing a murder was actually an undercover police officer. Did Miranda v. Arizona provide any protection to Perkins when the prosecution sought to use his confession at trial? The United States Supreme Court addressed this issue in Illinois v. Perkins.
Donald Charlton, an inmate, informed police officers that another inmate, Lloyd Perkins, had bragged about committing a murder. Charlton's description of the crime matched an unsolved murder that the officers had been investigating. As a result, the officers decided to place an undercover officer, John Parisi, in Perkins's cell block along with Charlton. Charlton introduced Perkins to Parisi, who pretended to be a member of a biker gang. Parisi claimed that he had killed someone and then asked Perkins if he had ever committed a murder. In response, Perkins provided Parisi with a detailed account of the unsolved murder. At no point during their conversation did Parisi reveal that he was a police officer or read Perkins his Miranda warnings.
A state prosecutor subsequently charged Perkins with murder and notified the defense that the state intended to use Perkins's confession to Parisi at trial. Perkins moved to suppress his incriminating statement to Parisi, arguing that it violated Miranda. The state trial court granted the motion, and the state appealed to the Appellate Court of Illinois, which affirmed the trial court's order. The Illinois Supreme Court then denied the state's leave to appeal. Ultimately, the state of Illinois successfully petitioned the United States Supreme Court to review Perkins's case.