Withholding the Miranda warnings until after a confession is obtained and then giving Miranda to re-ask the question has been found by the Supreme Court to be improper.

Question

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This is a form of the "question-first" or "reverse-Miranda" technique, which has been found to violate the Fifth Amendment's protection against self-incrimination. The Supreme Court has ruled that Miranda warnings must be given prior to any custodial interrogation, in order to inform the suspect of their right to remain silent and their right to counsel. Deliberately withholding Miranda warnings until after a confession has been obtained undermines the voluntariness and validity of the confession, and violates the suspect's constitutional rights.

Withholding the Miranda Warnings Until After a Confession Is Obtained