In United States v. Guzman-Bruno, 27 F.3d 420 (9th Cir. 1994), the defendant argued that the authorities only learned of his identity and of his criminal record because of their earlier illegal arrest of him.
In rejecting this argument that either his identity or his criminal record were excludable "fruits of the poisonous tree," the Ninth Circuit held:
Guzman-Bruno argues that the district court should have suppressed all evidence of his identity learned in connection with the illegal arrest. Because the government does not contest the district court's ruling that the arrest was illegal, we assume for purposes of our analysis that it was illegal ?.
A defendant's identity need not be suppressed merely because it is discovered as the result of an illegal arrest or search. "There is no sanction to be applied when an illegal arrest only leads to discovery of the man's identity. "The 'body' or identity of a defendant ... is never itself suppressible as a fruit of an unlawful arrest. (27 F.3d at 421-22.)