Seventh Circuit Remands Case Requiring Analysis of 'Knowing and Intelligent' Waiver Not Just Voluntariness

Shortly after cops arrested him for drug dealing, an Illinois man overdosed on heroin and fell unconscious. When he wakes up at the hospital, he says some incriminating stuff to the cops which led to federal charges. Man moves to suppress statements because he was in no condition to voluntarily, knowingly, and intelligently waive his Miranda rights. The district court finds the statements voluntary and admits them, and the man is convicted. Seventh Circuit: Sure, the statements weren't coerced. But the question of voluntariness is different from knowingly and intelligently waiver. Considering he was "unconscious and entirely incapacitated from an overdose just two hours before police questioned him, a finding on the former question matters." Please sort out on remand.