s: Illustrates that a procedural Miranda violation differs from Fourth Amendment violation, as the purpose of the Fourth Amendment exclusionary rule is to curb unreasonable search.Harris v New York: The Harris Court rejected the premise that a defendant's inadmissible confession entitles that defendant to "deny every fact disclosed or discovered as 'fruit' of his confession, free from confrontation with his prior statements." (401 U.S. 222) Failure to advise of Miranda rights creates a legal presumption of compulsion (of testimony,) but this compulsion does not prohibit the use of such statements in cross-examination.Michigan v Tucker: In Tucker, police used information garnered from a statement, made without Miranda warning, to uncover a witness. The Tucker Court established that this action was not in violation of the Wong Sun "fruits" doctrine. Miranda v Arizona: The Miranda Court set precedence that Miranda warnings will only be required after the accused has been taken into custody, or freedom has been restricted.United States v Bayer: Illustrates that once the accused "lets the cat out of the bag," he can't get the cat back in the bag - he will be at a disadvantage. "But this Court has never gone so far as to hold that making a confession under circumstances which preclude its use, perpetually disables the confessor from making a usable one after those conditions have been removed." (331 U.S., at 540-541)Lyons v Oklahoma: Establishes that even when a confession is forced, the coercive effect of the confession can be dissipated with time.Application: The Court asserted that although Elstad's admission made prior to Miranda advisement must be excluded, as per Miranda v Arizona, "The admissibility of any subsequent statement should turn in these circumstances solely on whether it was knowingly and voluntarily made." The Court affirmed that "There is no question that respondent knowingly and voluntarily waived his right to rema...
