Miranda Rights, Self Incrimination

Fruit of the poisonous tree Doctrine

An extension of the exclusionary rule; if the court decides that a piece of evidence was obtained illegally, then it is inadmissible in court.

• The fruit-of-the-poisonous tree doctrine is inapplicable unless physical evidence is found as a result of involuntary, coerced statements.

Fruit of the poisonous tree Doctrine exceptions

The evidence will not be excluded:

1. if it was discovered from a source independent of the illegal activity;

2. its discovery was inevitable;

3. or for evidence found as a result of excludable, voluntary testimony from the defendant

New York v. Quarles

Facts: A woman told the police that she had been raped by a man with a gun. The police followed the man and caught up to him. They searched him and did not find a gun. After handcuffing him, the officer asked Quarles where the gun was, and Quarles gestured with his head saying, “the gun is over there.” The officer found the gun and read Quarles his Miranda warnings. They then arrested him. The trial court held that the statement “the gun is over there,” must be excluded because it was elicited before the police read Quarles his Miranda warnings.

Issue: Whether there is a public safety exception to Miranda Rights

Holding: The statements are admissible

• The Fifth Amendment does not prohibit the admission of all incriminating statements. It merely prohibits the admission of coerced statements.

• the social cost of public safety outweighs a suspect’s constitutional safeguards. This is not coercive tactics

Rule: There a public-safety exception to the Miranda requirement; If public safety demands it, a suspect in police custody may be questioned without first being read his Miranda warnings

Dickerson v. United States

Facts: Dickerson (defendant) was indicted for bank robbery. Dickerson moved to have statements he made during an FBI interrogation suppressed, claiming he never received proper Miranda warnings.two years after Miranda v. Arizona, 384 U.S. 436 (1966) was decided, Congress passed 18 U.S.C. § 3501, which permits statements made by a suspect during a custodial police interrogation to be admitted at trial as long as they were made voluntarily.

Issue: Whether Miranda can be superseded by a by an act of Congress

Holding: No it cannot be

• Miranda decision acknowledged that it was establishing “constitutional guidelines for law enforcement agencies and courts to follow.”

• the doctrine of stare decisis forbids the overruling of Miranda.

Holding: Miranda v. Arizona, 384 U.S. 436 (1966), is a constitutional decision, and Congress cannot supersede it by passing legislation.

United States v. Patane

Facts: Arrested for harassing his gf. He was subjected to a restaining order. Officers tried to give him his Miraidna rights. Patane interrupted the officers to inform them he already knew the Miranda rights. The officer then asked about the gun, and Patane reluctantly allowed the officer to seize it.

Issue: Whether physical evidence found as a result of a suspect’s voluntary statements be suppressed because Miranda warnings were not given

Holding: The statements are admissible

• Self incrimination does not include physical evidence. 

• The Clause cannot be violated by the introduction of nontestimonial evidence obtained as a result of voluntary statements.

Rule: Because the introduction of physical evidence at trial does not implicate the Self-Incrimination Clause, suppression of physical evidence found as a result of a suspect’s voluntary but unwarned statements is not required.

Oregon v. Elstad

Facts: There was a robbery. Elstad is a teenager. Police were talking to Elstad bc he was a witness. At this point they had not suspected him and did not give him his Miranda rights. Elstad told the police he was there and they began to suspect him. They then took him the the station, gave him his Miranda rights.

Issue: If the police initially fail to administer a suspect his Miranda warnings, are subsequent statements that are made after the police administer the Miranda warnings, inadmissible because they are “tainted” by the initial failure?

• Whether the court can admit the statements from the second conversation bc it is fruit of the poisonous tree

Holding: 

• Elstad was not in custody during the first conversation

• Elstad said he understood his rights, the statements here were voluntary

• The second conversation is admissible 

• If there is a failure to warn for statement 1, any further statements will be admissible once it is demonstrated to be knowingly voluntarily made

Rule: A suspect can make a statement that is admissible in court after being read his Miranda warnings, even when he previously made an unwarned statement, because the initial failure to read a suspect his Miranda warnings does not taint later voluntary statements.