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Name: United States v. Patane
Case #: 02-1183
Court: US Supreme Court
District USSup
Opinion Date: 06/28/2004
Summary

A failure by police to give warnings under Miranda v. Arizona (1966) 384 U.S. 436 prior to interrogation does not require suppression of the physical fruits of unwarned but otherwise voluntary statements. The interrogating officer here attempted to give Miranda advisements but was cut off by the defendant, who said that he knew his rights. The lower federal courts suppressed physical evidence recovered as a result of the defendant’s subsequent admissions. A four-justice plurality held that suppression of physical evidence was not required because the Miranda rule protects against violations of the self-incrimination clause, and that clause is not implicated by the introduction of evidence acquired as the result of voluntary statements. The plurality noted that statements taken in violation of Miranda v. Arizona are only presumed to be involuntary in certain contexts, and then only when necessary to protect against violations of the self-incrimination clause. Justice Kennedy joined in the judgment but wrote separately to emphasize that it was not necessary to determine in this case whether the failure to provide advisements was even a violation of the Miranda rule, and that in his view the physical evidence was admissible under Oregon v. Elstad (1985) 470 U.S. 298 and Dickerson v. United States (2000) 530 U.S. 428.