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United States v. Patane


Officers approached the defendant at his home to discuss his possible connection to a gun crime and for violating a restraining order. After placing the defendant under arrest for violating the order, one of the officers began to read him the Miranda warnings. The defendant interrupted the officer, claiming to understand his rights. Without completing the Miranda warnings, the officer began questioning the defendant about a gun. The defendant volunteered several statements. He told the officers the gun was located in his residence and granted consent for its retrieval.


Whether the failure to provide adequate Miranda warnings prohibits the government from using physical evidence discovered as a result of this violation?


No. The Miranda rule protects against violations of the self-incrimination clause. This clause is not implicated by the admission into evidence the physical evidence found through voluntary statements made by the defendant.


The Court held that “[T]he Miranda rule is not a code of police conduct, and police do not violate the Constitution (or even the Miranda rule, for that matter) by mere failures to warn.” The primary protection afforded by the self-incrimination clause is a prohibition on compelling a defendant to testify against himself at trial. “Potential violations occur, if at all, only upon the admission of unwarned statements into evidence at trial.” The Court recognized that the Miranda rule sweeps beyond those protections actually found in the self-incrimination clause and is, therefore, reluctant to extend its reach without significant justification.

In the case at hand, the introduction of non-testimonial fruit of a voluntary statement does not implicate the self-incrimination clause. “The admission of such fruit presents no risk that a defendant’s coerced statements (however defined) will be used against him at a criminal trial.” Exclusion of the statements themselves serves as a complete remedy for any perceived Miranda violation. Note that the fruit of involuntary (through force or other coercive means) statements will continue to be suppressed.


542 U.S. 630, 124 S. Ct. 2620 (2004)

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