The Cellmate Confession

The Defendant was in custody at a county jail on an unrelated charge when police suspected him of an earlier, unsolved killing. Acting on a tip from a fellow inmate who said the Defendant had described the killing to him, police placed an undercover officer in the Defendant's cellblock, posing as an escapee awaiting transfer after a burglary arrest. The informant was placed in the same cellblock, also posing as an escapee. During their conversations about a possible escape, the undercover officer asked whether the Defendant had ever "done" anybody. The Defendant then described the earlier killing in detail — where it happened, how it was planned, the weapon used, and payment he said he received. At no point in these conversations did the undercover officer identify himself as law enforcement or give the Defendant a Miranda warning.