Some Missouri police officers conduct an interrogation without Miranda warnings. They secure a confession and then give the Miranda warnings thereafter and obtain a second confession. The U.S. Supreme Court has struck down this practice calling it the “Missouri Two-Step.”
The second confession, obtained after warnings are given, is inadmissible.
It is remotely possible, if the court finds that the officer did not obviously attempt to bypass the Miranda requirements and there is proof that the second confession is “attenuated” or somewhat remotely disconnected to the first confession, that the second confession still may be admissible.
The U.S. Supreme Court has addressed the subject holding that the Missouri two-step will only render a statement inadmissible if the officer uses the technique in a “calculated way to undermine the Miranda warning.”
Officers must be very careful to obey the restrictions in Miranda v. Arizona. The best course is don’t dance the Missouri Two-Step!
 Missouri v. Seibert, 542 US 600 (2004).
 State v. Williams, 163 SW3d 522 (MO App 2005).
 State v. Gaw, 285 SW3d (Mo banc 2009).
 Miranda v. Arizona, 384 US 436 (1964).