Supreme Court: Physical Evidence in Miranda Settings
Devanney, Joe, Law & Order
In June 2004, the United States Supreme Court, in a 5-4 decision, issued an important ruling concerning how Miranda warnings relate to the suppression of physical items seized by police. The question before the Court in this case, which started from Colorado, was whether the "physical fruits" (physical evidence) discovered as a result of voluntary, but unwarned, statements had to be suppressed. The Court, in an opinion written by Justice Thomas, determined that such seized physical items do not have to be suppressed and can be used at trial.
As with many cases that end before the Supreme Court, this one originated from a relatively small incident. In June 2001, officers from the Colorado Springs Police Department were assigned to investigate whether Samuel Frances Patane violated a restraining order by attempting to call his ex-girlfriend. Patane, as a convicted felon, was prohibited from possessing firearms, but the police had received a tip from the Bureau of Alcohol, Tobacco and Firearms that Patanc owned a Gloek pistol.
The officers went to Patane' home and arrested him for violating the restraining order. Detective Josh Benner tried to advise Patane of his Miranda rights, but Patane cut him off and responded that he knew his rights. Without completing the warnings, Benner then asked Patane about the pistol. Patane, after some reluctance, stated that the pistol was in a bedroom. The police searched there, found the weapon and took it for evidence.
At trial in the United States District Court, Patane moved to suppress the weapon, but lost. Heappealed to the Tenth Circuit Court of Appeals. This Court reversed the trial court and the government appealed its decision to the Supreme Court.
The Supreme Court, in its decision, first noted that the Miranda Rule is meant to protect only against violations of the Self-Incrimination Clause. This clause reads "No person...shall be compelled in any criminal case to be a witness against himself." The basic intent of the clause is, wrote Justice Thomas, only that a person not be compelled to testify orally against themselves at trial.
There is, according to him, no violation of the Self-Incrimination Clause by the admission of "physical fruits" discovered by police as a result of a defendant's voluntary statement, even if Miranda is violated.
Justice Thomas even wrote that "[A] mere failure to give Miranda warnings does not, by itself, violate a suspect's constitutional rights or even the Miranda rule [itself]." There is not even a constitutional problem if police deliberately or negligently fail to give the warnings. The problem of incomplete or absent Miranda warnings, however, does occur if the statements are admitted at trial.
At that point, per Justice Thomas, the suppression of such statements is a "complete and sufficient remedy" for any Miranda violations. Justice Thomas continued, "Thus, unlike unreasonable searches under the Fourth Amendment or actual violations of the Due Process Clause or the Self-Incrimination Clause, there is, with respect to mere failures to warn, nothing to deter. There is therefore no reason to apply the 'fruit of the poisonous tree' doctrine. …