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

Facts

Gross’ home was burglarized and witnesses saw Elstad.  Officers arrived at Elstad’s parents home, led Elstad into the living room, told him they thought he was involved, and Elstad admitted his involvement.  Elstad was taken to the Sheriff’s office, where he was advised of his Miranda rights for the first time.

Procedural History

Elstad moved to suppress his oral statements and signed confession, stating that the confession at the house “let the cat out of the bag” and tainted the subsequent confession as “fruit of the poisonous tree.”  The trial court suppressed the statement at the home but allowed the subsequent confession.  The Court of Appeals reversed.

Issue(s)

Did the Court of Appeals err in finding that the constitutional inquiry was whether there was a sufficient break in the stream of events between the inadmissible statement and the written confession to insulate the later statement for the effect of what went before?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that the Oregon court assumed that failure to administer Miranda warnings breeds the same consequences as police infringement of a constitutional right, so that evidence uncovered must be suppressed as fruit of the poisonous tree.  Elstadd’s contention assumes the existence of a constitutional violation.  In Tucker, unwarned questioning did not abridge constitutional privilege but departed from prophylactic standards and since there was no constitutional infringement, the case was not controlled by Wong Sun (fruit of the poisonous tree).  A suspect who has once responded to unwarned yet uncoercive questioning is not thereby disabled from waiving his rights and confessing after he has been given the requisite Miranda warnings.

Judgment/Outcome

The Court reversed the judgment of the Oregon Court of Appeals.