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Abstract: 

U.S. v. Higgins-Vogt, 911 F.3d 814 (7th Cir. 2018), deals with an ersatz jail counselor, serving as an agent of law enforcement. She draws out a confession of murder from an accused who was in jail on charges of armed robbery. With a support boost from “counselor” Brown, the suspect confessed to murdering his accomplice in the robbery. There was deception from the inception. Higgins-Vogt clearly came to trust his counselor, who then smoothed the way to a “voluntary conscience clearing” act of confessing a murder to a detective.

Keywords: Miranda warnings

Affiliations:  1: Executive Editor.