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In Oregon v. Elstad (1985), the parties in the case were Michael Elstad, an 18-year-old charged with burglary, and the State of Oregon. When arrested, Elstad made incriminating statements before police officers read him the required Miranda warning. At the police station, the officers administered the Miranda warning, and Elstad waived his rights and wrote a confession.
At trial, Elstad was convicted of the burglary. His lawyers appealed the conviction, and the Oregon Court of Appeals overturned it on the grounds that Elstad’s written confession should have been excluded from evidence because he had not been Mirandized before his initial statements. The State of Oregon (petitioner) disagreed with the decision and appealed to the U.S. Supreme Court (making Elstad the respondent).
The Supreme Court reversed the Oregon Court. It held that the Fifth Amendment’s self-incrimination clause “does not require the suppression of a confession, made after proper Miranda warnings and a valid waiver of rights, solely because the police had obtained an earlier voluntary but unwarned admission from the suspect.”
The Court refused to extend the “fruit of the poisonous tree” doctrine to the Fifth Amendment, which protects criminal defendants from self-incrimination (the right to remain silent). That doctrine is part of the exclusionary rule, which directs that evidence obtained from an unreasonable search, illegal arrest, or intimidating questioning must be excluded at trial.
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