## Facts

- Police investigated Samuel Francis Patane for violating a temporary restraining order obtained by his ex-girlfriend; officers also received information that Patane, a convicted felon, possessed a pistol.
- Officers went to Patane’s home and arrested him for the restraining-order violation.
- An officer began giving Miranda warnings, but Patane interrupted and stated he knew his rights; the officer stopped the warnings.
- Officers questioned Patane about the pistol; Patane disclosed its location in his bedroom and directed officers to it.
- Officers seized a Glock pistol.
- Patane was charged in federal court with felon-in-possession of a firearm under 18 U.S.C. § 922(g)(1).

## Issues

1. Whether a failure to administer Miranda warnings requires suppression of physical evidence discovered as a result of a suspect’s unwarned but voluntary statement.

## Decision

- The Supreme Court reversed the court of appeals and remanded.
- A plurality concluded that a mere failure to give Miranda warnings does not require suppression of physical fruits derived from unwarned but voluntary statements.
- A separate concurrence agreed with admitting the gun on narrower grounds, stressing the absence of coercion and the exclusion of the unwarned statements themselves from trial.
- Dissents would have applied a “fruit of the poisonous tree” rule to suppress the gun obtained through questioning conducted without Miranda warnings.

## Legal Principles

- The Self-Incrimination Clause primarily bars compelled testimonial evidence being used against a defendant at trial; it does not, by itself, bar admission of nontestimonial physical evidence derived from voluntary statements.
- Miranda is a court-crafted safeguard for the privilege against self-incrimination; an unwarned but voluntary statement is excluded from the prosecution’s case-in-chief, but that prophylactic rule does not automatically extend to derivative physical evidence.
- Derivative-evidence exclusion is generally tied to actual constitutional violations such as coercion; where statements are voluntary and only Miranda warnings are missing, suppression of physical fruits is not required.
- Courts must distinguish between (a) coerced statements, which can taint derivative evidence, and (b) unwarned but voluntary statements, which typically do not.

## Conclusion

The Court held that when police obtain an unwarned but voluntary statement, the Fifth Amendment does not require suppressing physical evidence discovered as a result, even though the unwarned statement itself is generally inadmissible.


United States v. Patane, 542 U.S. 630 (2004)