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
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
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