Oregon v. Elstad
Citation and Court
470 U.S. 298 (1985) — Supreme Court of the United States
Facts
Officers went to Elstad’s home to arrest him. Before giving Miranda warnings, one officer briefly asked Elstad about a burglary and Elstad made an incriminating statement. At the police station, officers read Elstad his Miranda rights and he signed a waiver, then gave a full, voluntary confession. He moved to suppress the second statement as fruit of the first.
Issue
Whether a voluntary confession obtained after proper Miranda warnings is inadmissible simply because the police had previously obtained an un-Mirandized statement from the same suspect.
Holding
No; a midstream Miranda warning and subsequent voluntary waiver breaks the causal connection between an earlier un-Mirandized statement and a subsequent confession, making the second statement admissible.
Rule / Doctrine
Because Miranda warnings are prophylactic rather than constitutionally mandated confessions of rights, the fruit-of-the-poisonous-tree doctrine does not automatically require suppression of a second, properly warned confession. If the first, un-Mirandized statement was voluntary (not coerced), giving proper warnings before the second statement is sufficient to ensure its admissibility — as long as the second statement is itself voluntary.
Significance
Declined to extend the fruit-of-the-poisonous-tree doctrine to the Miranda context, treating Miranda violations differently from actual Fifth Amendment violations. Later qualified by Missouri v. Seibert (2004), which held that a deliberate two-step interrogation strategy designed to circumvent Miranda requires more than a midstream warning cure.