## Facts

- A home in Polk County, Oregon, was burglarized; a witness implicated Michael James Elstad, age 18.
- Police obtained an arrest warrant and went to Elstad’s home, where his mother admitted them and led them to his bedroom.
- Elstad was taken to the living room; before any Miranda warnings, an officer stated he believed Elstad was involved, and Elstad admitted he had been there.
- Elstad was transported to the sheriff’s office.
- About an hour later, officers administered Miranda warnings; Elstad said he understood, waived his rights, and gave a detailed written confession.

## Issues

1. Whether the Fifth Amendment requires suppression of a post-Miranda confession, made after proper warnings and a valid waiver, solely because police earlier obtained a voluntary but unwarned admission.

## Decision

- The Supreme Court reversed the Oregon Court of Appeals and reinstated the conviction.
- A prior voluntary but unwarned admission does not, by itself, require exclusion of a later confession made after proper Miranda warnings and a valid waiver.
- The relevant inquiry is whether the later statement was knowingly and voluntarily made under traditional voluntariness standards.

## Legal Principles

- An unwarned custodial statement is excluded from the prosecution’s case-in-chief because Miranda creates a presumption of compulsion, even if the statement was otherwise voluntary.
- A Miranda violation, without actual coercion, does not automatically taint subsequent statements; an automatic “fruit of the poisonous tree” rule does not apply to mere failures to warn.
- If the first statement was actually coerced, courts consider whether coercion carried over (including time lapse, change of location, and change of interrogators).
- When the initial statement is voluntary but unwarned, a careful administration of Miranda warnings can render a subsequent waiver effective, and the later warned statement is admissible if voluntary, knowing, and intelligent.

## Conclusion

The Court held that a suspect who makes a voluntary but unwarned admission is not thereby barred from later waiving Miranda rights and giving an admissible confession after proper warnings, so long as the later statement is voluntary and the waiver is valid.


Oregon v. Elstad, 470 U.S. 298 (1985)