Ex Parte J.D.H
In Ex Parte J.D.H., 797 So. 2d 1130, 1132 (Ala. 2001).the Alabama Supreme Court held that Miranda warnings were not effective for a confession given sixteen days later.
The court recognized "a line of cases" from that state's Court of Criminal Appeals "holding that once Miranda warnings have been given and the defendant has made a knowing, intelligent, and voluntary waiver, a failure to repeat the warnings will not automatically preclude the admission of an inculpatory statement."
The Supreme Court distinguished those cases by observing that "in none of those cases did the lapse exceed a few days without at least a reminder of the warnings."
In holding the confession inadmissible, the court found that the time lapse of twelve hours was relatively long, that the confession occurred in the same building but in a different room (warnings administered in large homicide division office while statement given in small interrogation room), the officer securing the confession was different than the officer giving the warnings, and the later statements were materially different from earlier statements given immediately after the warnings.