Oregon v. Elstad (1984)

Docket
83-773
Decided
1984-01-01

Summary

Question: Was Elstad's written confession made invalid by the failure of the officers to administer Miranda warnings at his home? Conclusion: In a 6-to-3 decision, the Court held that while Miranda required that unwarned admissions must be suppressed, subsequent statements, if made knowingly and voluntarily, need not be. The Court held that ". . .the mere fact that a suspect has made an unwarned admission does not warrant a presumption of compulsion." The Court also noted that police officers were ill-equipped to determine when "custody" legally begins. Justice O'Connor, writing for the majority, argued that the holding "in no way retreat[ed] from the bright-line rule of Miranda."

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