Wong Sun v. United States

371 U.S. 471, 83 S. Ct. 407 (1963)

 

RULE:

A court need not hold that all evidence is "fruit of the poisonous tree" simply because it would not have come to light but for the illegal actions of the police. Rather, the more apt question in such a case is whether, granting establishment of the primary illegality, the evidence to which an objection is made has been come at by exploitation of that illegality or instead by means sufficiently distinguishable to be purged of the primary taint.

FACTS:

In light of the circumstances surrounding the case, was the presented evidence admissible so as to convict the petitioners with the crime charged against them?    

ISSUE:

In light of the circumstances surrounding the case, was the presented evidence admissible so as to convict the petitioners with the crime charged against them?    

ANSWER:

No.

CONCLUSION:

The court held that an out-of-court declaration made after an arrest may not be used at the trial against one of the declarant's partners in a crime unless the statement was made in furtherance of the criminal undertaking. Expounding, the Court posited that the arrests were held without probable cause. As to petitioner Toy, the Court expressed the view that his flight when the officers appeared at his door did not justify an inference of guilt sufficient to generate probable cause. Moreover, Toy's declarations in his bedroom should be excluded as the "fruits" of the officers' unlawful action and such exclusion also required the exclusion of the narcotics surrendered by Yee. More importantly, Toy's unsigned statement was not corroborated and hence furnished no basis for his conviction. With regard to petitioner Wong, it was held that his unsigned confession and the heroin surrendered by Yee were admissible against him because not the fruit of the unlawful arrest. Furthermore, any references to Wong in Toy's statement were incompetent to corroborate Wong's confession; because of this, it was ruled that Wong was entitled to a new trial because it was not certain from the record whether the trial court might not have considered the contents of Toy's statement as against Wong. In general, the convictions against the petitioners were vacated and they were granted a new trial based on a chain of inferences indicating prejudicial error in that the trial court may have considered each petitioner's statement as corroboration of the other petitioner's guilt, thus violating the rule that a co-conspirator's hearsay statements were admissible against an accused only if made during and in furtherance of the conspiracy.

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