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The failure to deliver Miranda warnings is not itself a constitutional violation. As a result, the fruit of the poisonous tree analysis is inapplicable in cases involving mere departures from Miranda. Accordingly, derivative evidence obtained as a result of an unwarned statement that was voluntary under the Fifth Amendment is never fruit of the poisonous tree. The fruit of the poisonous tree doctrine does not apply to evidence obtained as a result of an unwarned statement if the statement was voluntary under the Fifth Amendment.
Defendant was indicted on two counts of making a false statement to a firearms dealer and on one count of impersonating an accredited diplomat. Defendant moved to suppress, among other things, the firearms and firearms receipts found in his hotel rooms, the firearms transaction records obtained from the firearms dealer, and the testimony of the individual at the firearms dealer who sold the firearms to the defendant. The district court suppressed the evidence as the "tainted fruit" of a Miranda violation. The district court also ruled that the warned and voluntary statements defendant made at the detention center, in which he identified the firearms seized from his hotel rooms and the firearms dealer that sold him the weapons, did not constitute an "independent source" for admitting any of the challenged evidence. The government sought review of the district court’s decision, arguing that the district court erred in applying the "fruit of the poisonous tree" doctrine to the challenged evidence in the case.
Did the district court err in in applying the "fruit of the poisonous tree" doctrine to the challenged evidence in question?
Upon appeal, the court reversed finding that the fruit of the poisonous tree analysis was inapplicable as there was only a mere departure from Miranda. The court found that the derivative evidence obtained as a result of an unwarned statement that was voluntary under the Fifth Amendment was not fruit of the poisonous tree. The court found no evidence that the police officers, to whom defendant had made statements regarding the evidence in question, used any technique or method that would offend due process. The court also held that defendant voluntarily consented to the search of his hotel rooms.