Patterson v. United States
Headline: Court refuses to review whether items found after questioning without Miranda warnings are admissible, leaving the appeals court’s ruling in place and the nationwide split unresolved.
Holding: The Court denied review of a Ninth Circuit decision that allowed physical evidence obtained after questioning without Miranda warnings to be used, while Justice White (joined by Brennan) dissented and would have granted review.
- Leaves courts divided on admitting evidence after Miranda-violating questioning.
- Allows evidence seized after such questioning to be used in the Ninth Circuit.
- Creates uncertainty for defendants questioned without Miranda warnings.
Summary
Background
A man was arrested in Mexico after trying to pass a counterfeit $20 bill. While still in Mexican custody, United States Secret Service agents questioned him but did not give Miranda warnings (police warnings about the right to remain silent and to an attorney). He described a counterfeiting operation in San Diego, agents used that information to get a search warrant, and officers seized evidence from the described location. He asked courts to suppress that physical evidence as coming from questioning that violated Miranda.
Reasoning
The core question was whether physical items discovered because of a Miranda-violating interrogation must be excluded from use at trial. The Ninth Circuit rejected the suppression claim, relying in part on its own prior decisions and on the Supreme Court’s earlier discussion in Elstad, which did not directly resolve this exact issue. The Supreme Court declined to review the Ninth Circuit’s ruling, leaving the appeals court decision intact. The Court did not resolve the broader split among state and federal courts on the question.
Real world impact
Because the Supreme Court denied review, the split among courts remains. In the Ninth Circuit, evidence tied to questioning without Miranda warnings can be used under existing precedent; other circuits may differ. The denial is not a final ruling on the legal question and could be revisited if the Court takes a future case squarely presenting the issue.
Dissents or concurrances
Justice White, joined by Justice Brennan, dissented and would have granted review to resolve the disagreement among courts nationwide.
Opinions in this case:
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