United States v. Patane

United States v. Patane Case Brief

United States Supreme Court
542 U.S. 630 (2004)

ISSUE: Does the failure to give a suspect his Mirandawarnings require suppression of the physical fruits of the suspect's unwarned but voluntary statements?
HOLDING: No.
FACTS:
  • Patane was arrested for harassing his ex-girlfriend and was released with a TRO not to contact his ex
  • He then tried to call his ex, who then told the police
  • 2 officers then went to D's residence after finding out that ATF that D was illegally possessing a Glock b/c he was a convicted felon
  • D was arrested and an officer attempted to Mirandize him, but D interrupted and said that he understood his rights
  • An officer then asked about the gun, and D told him it was in his bedroom
PROCEDURAL HISTORY:
  • Dist. Ct. suppressed the firearm, concluding that the officers lacked PC to arrest D for violating the TRO
  • Ct. App. reversed Dist. Ct. on PC determination but affirmed suppression on Miranda violation
REASONING:
  • No suppression of physical evidence: The Self-Incrimination Clause is not implicated by the admission into evidence of the physical fruit of a voluntary statement, and thus there is no justification for extending the Miranda rule into this context
    • Exclusionary Rule is thus inappropriate
    • Test of 5th Amdt. is self-executing, so further expansion of Miranda is unwarranted
  • No constitutional violation: Mere failure to giveMiranda warnings does not, by itself, violate a suspect's constitutional rights or even the Miranda rule
    • Exclusion of the unwarned statements is a complete and sufficient remedy for any perceived Miranda violation
    • Nothing to deter with failures to warn
COMMENTS:
  • Rule: No violation of the Self-Incrimination Clause by introduction of the physical fruits of a voluntary but unwarned statement

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