State v. Lee

In State v. Lee, 175 Wis. 2d 348, 359, 499 N.W.2d 250 (Ct. App. 1993), after analyzing the relevant United States Supreme Court and Wisconsin cases, the Court held that even when there is no police coercion and the statement is therefore voluntary, the State must make a separate showing that the waiver of Miranda rights is knowing and intelligent in order for the statement to be admissible. Lee, 175 Wis. 2d at 352, 356.