Stephen Breyer,
Missouri v. Seibert — Concurrence
“ I believe the plurality's approach in practice will function as a "fruits" test. The truly "effective" Miranda warnings on which the plurality insists, ante, at 615, will occur only when certain circumstances—a lapse in time, a change in location or interrogating officer, or a shift in the focus of the questioning—intervene between the unwarned questioning and any postwarning statement. ”
