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.

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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)

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Michigan v. Tucker citedBy United States v. Patane