United States v. Patane
542 U.S. 630, 124 S.Ct. 2620, 159 L.Ed.2d 667 (2004)

  • Patane was arrested outside his house. The police started to read him the Miranda Warning, but Patane interrupted saying, “I know my rights!” The police asked him where his gun was hidden. He proceeded to tell them.
    • Patane was a convicted felon, and so it was illegal for him to possess a weapon.
  • The Trial Court found that Patane was in illegal possession of a firearm. (However they found that the police didn’t have probable cause to have arrested him.) The prosecutor appealed.
    • At trial, the prosecutor had introduced the gun into evidence, but never introduced Patane’s statement, or made any mention of how the police found the gun.
      • Since the gun was in Patane’s house, it was pretty obvious to the jury that it was his, the jury didn’t need an admission from Patane.
  • The Appellate Court found that the police had probable cause, but that the gun was not admissible evidence. The prosecutor appealed.
    • The Appellate Court found that the evidence was ‘fruit of the poisonous tree’ because the recent case of Dickerson v. United States (530 U.S. 428 (2000)) had said that failure to give the Miranda Warning was a Constitutional violation of the 5th Amendment.
  • The US Supreme Court reversed and found that the gun was admissible into evidence.
    • The US Supreme Court found that the Miranda Warning is a prophylactic employed to protect against violations of the Self Incrimination Clause of the 5th Amendment. However, that doesn’t apply to the ‘physical fruit’ of a voluntary statement.
    • The Court found that the police do not violate a suspect’s Constitutional rights by negligent or even deliberate failures to provide a Miranda Warning. The violation only happens when the admission is entered into evidence.
      • The Court agreed that the exclusion of such statements is a complete and sufficient remedy.
    • The Court found that the whole point of the ‘fruit of the poisonous tree’ argument with regards to unreasonable searches was to deter the police from violating the 4th Amendment. But here, since the failure to give a Miranda Warning (by itself) doesn’t violate the 5th Amendment there is nothing to deter, therefore there is no reason to exclude the evidence.
  • In a dissent it was argued that allowing any evidence obtained from a Miranda Warning violation would encourage the police to not give Miranda Warnings.
    • “There is no way to read this case except as an unjustifiable invitation to law enforcement to flaunt Miranda when there may be physical evidence to be gained.”
  • Basically, this case said that the Miranda Warning is just to stop a person from being compelled to give self-incriminating statements. As long as the statement itself is not admitted into evidence, any other evidence that the police find as a result of hearing the statement is perfectly admissible.