State v. Armstrong

¶1. These cases are before the court on certification by the court of appeals, pursuant to Wis. Stat. § (Rule) 809.61 (1995-96). Police officers investigating a homicide interviewed Tonnie D. Armstrong (Armstrong) at the county jail, where Armstrong was serving time for an unrelated offense. Armstrong made oral statements incriminating himself in the homicide. At the end of the interview, the officers administered the Miranda warnings 2 to Armstrong for the first time. About two hours later, they presented Armstrong with a written statement memorializing the earlier unwarned statements.…