Ex Parte Bagley

In Ex Parte Bagley, 509 S.W.2d 332, 335 (Tex. Crim. App. 1974) the suspect was given Miranda warnings by arresting officers and by a magistrate. Subsequent warnings were given before a polygraph exam and before the complained of statement, but it was not completely clear that these subsequent warnings were adequate. Although this Court ultimately decided that the warning immediately preceding the statement was adequate, we also found that the warnings given six to eight hours earlier would have satisfied the dictates of Miranda. In connection with our discussion, we cited some out-of-state cases for the proposition that Miranda warnings "are not to be accorded unlimited efficacy or perpetuity" but were also not automatically extinguished by the mere passage of time. The Court cited two out-of-state cases for the proposition that Miranda warnings may be considered effective for statements given two or three days later. The Court also cited a previous Texas case dealing with Article 15.17, Texas Code of Criminal Procedure, admonishments for the proposition that warnings may effectively cover a confession given six days later. Bagley, 509 S.W.2d at 338.