United States v. Patane
E822433
United States v. Patane is a U.S. Supreme Court decision that limited the exclusionary rule by holding that physical evidence obtained as a result of unwarned but voluntary statements is admissible despite a Miranda violation.
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
Miranda doctrine case
ⓘ
U.S. Supreme Court case ⓘ criminal procedure case ⓘ |
| areaOfLaw |
Fifth Amendment
NERFINISHED
ⓘ
criminal procedure ⓘ self-incrimination ⓘ |
| citation | 542 U.S. 630 ⓘ |
| citationStyle | United States v. Patane, 542 U.S. 630 (2004) NERFINISHED ⓘ |
| concurrenceBy |
Anthony M. Kennedy
NERFINISHED
ⓘ
William H. Rehnquist NERFINISHED ⓘ |
| constitutionalProvisionInterpreted |
Self-Incrimination Clause
NERFINISHED
ⓘ
U.S. Constitution, Fifth Amendment NERFINISHED ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| decisionDate | 2004-06-28 ⓘ |
| dissentBy |
David H. Souter
NERFINISHED
ⓘ
John Paul Stevens NERFINISHED ⓘ Ruth Bader Ginsburg NERFINISHED ⓘ Stephen G. Breyer NERFINISHED ⓘ |
| evidenceTypeAtIssue |
handgun
ⓘ
physical evidence ⓘ |
| factPattern |
Defendant interrupted Miranda warnings and admitted to possessing a gun.
ⓘ
Police, relying on the unwarned admission, recovered a handgun from the defendant’s residence. ⓘ |
| fullCaseName | United States v. Samuel Francis Patane NERFINISHED ⓘ |
| holding |
A failure to give Miranda warnings does not require suppression of physical fruits of a suspect’s unwarned but voluntary statements.
ⓘ
Physical evidence obtained as a result of unwarned but voluntary statements is admissible at trial. ⓘ The Self-Incrimination Clause is not implicated by the introduction at trial of physical evidence resulting from voluntary statements. NERFINISHED ⓘ |
| impact |
allowed admission of physical fruits of unwarned but voluntary statements
ⓘ
limited the scope of the Miranda exclusionary rule ⓘ |
| issue |
admissibility of physical evidence derived from unwarned statements
ⓘ
scope of the exclusionary rule for Miranda violations ⓘ |
| joinedByInPlurality |
Anthony M. Kennedy
NERFINISHED
ⓘ
Antonin Scalia NERFINISHED ⓘ William H. Rehnquist NERFINISHED ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| languageOfOpinion | English ⓘ |
| legalRule |
Miranda’s exclusionary rule is a prophylactic rule that does not extend to physical fruits of unwarned but voluntary statements.
NERFINISHED
ⓘ
Only unwarned statements themselves, not derivative physical evidence, are generally subject to suppression under Miranda. ⓘ |
| lowerCourt | United States Court of Appeals for the Tenth Circuit NERFINISHED ⓘ |
| lowerCourtDisposition | suppressed the handgun as fruit of a Miranda violation ⓘ |
| majorityOpinionBy | Clarence Thomas NERFINISHED ⓘ |
| pluralityOpinionBy | Clarence Thomas NERFINISHED ⓘ |
| relatedDoctrine |
Miranda v. Arizona
NERFINISHED
ⓘ
exclusionary rule ⓘ fruit of the poisonous tree doctrine ⓘ |
| supremeCourtDisposition | reversed the judgment of the Tenth Circuit ⓘ |
| term | October Term 2003 NERFINISHED ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.