Commonwealth v. Wideman

In Commonwealth v. Wideman, 460 Pa. 699, 334 A.2d 594, 596 (Pa. 1975) the Pennsylvania Supreme Court invalidated a confession taken twelve hours after the administration of Miranda warnings. Acknowledging earlier Pennsylvania cases holding that an accused need not always be reinformed of his Miranda rights, the court set forth a five-factor balancing test for determining when previously given warnings lose their effectiveness. The court would consider: (1) the time lapse between the last Miranda warnings and the accused's statement; (2) interruptions in the continuity of the interrogation; (3) whether there was a change of location between the place where the last Miranda warnings were given and the place where the accused's statement was made; (4) whether the same officer who gave the warnings also conducted the interrogation resulting in the accused's statement; (5) whether the statement elicited during the complained of interrogation differed significantly from other statements which had been preceded by Miranda warnings. Id.