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Post-Miranda
Cases:
How the Supreme Court of the United States Decided
Harris
v. New York (1971)
The Court said that Miranda did not mean that evidence
barred from use during the prosecution's case could not
be used for any purpose. They said the Miranda protection
could not be "perverted into a license to use perjury
by way of a defense, free from the risk of confrontation
with prior inconsistent utterances."
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Michigan
v. Tucker (1974)
The
Court ruled that the witness could testify. In this case they
made a distinction between a violation of the Fifth Amendment
right against self-incrimination and a mere violation of the
Miranda rule. Since the defendant was warned about
his right against self-incrimination, the Court allowed the
witness to testify.
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Oregon
v.
Elstad
(1985)
The
Court ruled that admissions made prior to Miranda warnings
must be suppressed, but later statements, if made voluntarily,
may be used in court. "[T]he mere fact that a suspect
has made an unwarned admission does not warrant a presumption
of compulsion," Justice O'Connor wrote.
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Illinois
v.
Perkins
(1990)
Justice
Kennedy, writing for the majority, held that conversations
between suspects and undercover officers are not held in a
"police-dominated atmosphere" and therefore Miranda
warnings are not necessary. No coercion was possible because
there was no official interrogation.
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New
York v. Quarles (1984)
The
Court said there is a "public safety" exception
which applies in this case. The police officer acted to further
public safety and therefore the statement made by the defendant
telling of the location of the weapon) before his Miranda
rights were read to him was admissible in court.
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