Michigan v. Tucker

In Michigan v. Tucker, 417 U.S. 433 (1974), the defendant was arrested and interrogated concerning the rape and assault of the defendant's neighbor. Prior to interrogation, police officers inquired whether the defendant knew for what crime he had been arrested, whether he wanted an attorney, and whether he understood his constitutional rights. The police further advised him that any statements he made could be used against him in court but the defendant was not informed that he would be furnished an attorney if he could not afford one. During the ensuing interrogation, the defendant furnished the name of an alibi witness. The police questioned the witness but rather than providing an alibi for the defendant, the witness supplied the police with information inculpating the defendant. At trial, the defendant sought to suppress the witness's testimony under the fruit of the poisonous tree doctrine. The defendant asserted that the witness's testimony should be excluded because the witness's identity was revealed during an interrogation which was not preceded by complete Miranda warnings. On appeal, the Court noted that the Miranda warnings were not constitutional rights themselves but were instead measures to insure that the right against compulsory self-incrimination was protected. The Court determined that the police conduct at issue did not actually violate the defendant's constitutional rights against compulsory selfincrimination but, rather, inadvertently violated the procedural rules set forth in Miranda. Because there was no violation of the defendant's constitutional rights under the Fifth Amendment, the Court held that the fruit of the poisonous tree doctrine was inapplicable. The Court further held that the purposes of the exclusionary rule--deterrence and protection of the courts from reliance on untrustworthy evidence--would not be served by excluding the alibi witness's testimony because the police officers who interrogated the defendant did not coerce the defendant into making a statement nor did they subject the alibi witness to custodial pressures. The Court thus held that, although the defendant's own statements must be suppressed pursuant to Miranda, the fruit of those statements--the alibi witness's testimony--need not be excluded. The Supreme Court was asked to apply the "tainted fruits" doctrine to the testimony of a witness whose identity was discovered as the result of a statement obtained in violation of Miranda. In declining to extend the doctrine to the facts in Tucker, the Supreme Court noted that the unwarned questioning did not abridge Tucker's Fifth Amendment privilege, "but departed only from the prophylactic standards later laid down by this court in Miranda to safeguard that privilege." 417 U.S. at 445-446. Because Tucker's constitutional rights were not infringed, the Court determined that the "fruit of the poisonous tree" doctrine did not apply. 417 U.S. at 445 n.19. A As a result, although the direct evidence (Tucker's unwarned statement) had to be suppressed, the derivative evidence (the testimony of the witness discovered as a result of the unwarned statement) was admissible. See 417 U.S. at 445-446.