Perhaps this is what Allen County Karen Richards was afraid of when she decided to reach a plea agreement with Simon Rios that gave him a life sentence instead of the death penalty:
CINCINNATI - A death row inmate convicted of setting a fire that killed five children must be released or retried because his constitutional rights were violated when his confession was used at trial, a federal appeals court panel ruled Tuesday.
The 6th U.S. Circuit Court of Appeals judges ruled 2-1 that William Garner didn't understand his right to silence when he told police he would waive his Miranda rights against self-incrimination. He gave a taped statement to police, saying he set fire to aapartment with six children inside to destroy evidence of his burglary, according to court records.
[. . .]
Judge Karen Nelson Moore, joined by Judge Boyce L. Martin, wrote that evidence showed that Garner, 19 at the time of the statement, was poorly educated and had low intelligence and other limitations directly related to understanding and comprehending his rights. Expert testimony also showed that Garner didn't understand the word "right" or his right to remain silent, their opinion stated.
How smart do you have to be? Garner understood that there was evidence that could convict him and that a fire could destroy the evidence.