UNITED STATES v. PATANE

No. 02-1183

SUPREME COURT OF THE UNITED STATES

Argued on February 24th, 2004

Decided on March 11th, 2004

OPINION OF THE COURT DELIVERED JOINTLY BY Justices Biddle, and Klein, and Hanson

This case requires us to decide whether Samuel Patane's pistol, as the physical fruit of a Miranda violation, should be admitted into evidence.

The opinion of this court will approach the case from two separate areas, dealing first with the nature of the actual Miranda violation and secondly, determining if the gun's seizure was a result of inevitable discovery or the primary result of the confession received under the Miranda violation.

In failing to inform Patane of the his entire Miranda rights, Detective Benner violated Patane's constitutionally guaranteed right against self-incrimination. More specifically, the incomplete warning failed to inform Patane of the consequences of foregoing this right. As the defense argues in citing Miranda v. Arizona, "It is only through an awareness of these consequences that there can be any assurance of real understanding and intelligent exercise of the privilege." Acknowledging the defendant's statement in which he told Detective Benner "I know my rights", the court reminds the officer that” Assessments of the knowledge the defendant possessed, based on information as to his age, education, intelligence, or prior contact with authorities, can never be more than speculation; a warning is a clear-cut fact." While it is sometimes true that the lack of Miranda rights may be inconsequential, the failure to properly administer Miranda warnings is on-point to what Patane was prosecuted for. The larger issue thean is if the proceeding events are inadmissible as a result of the preceding violation.

One such exception to Miranda that the plaintiff argues for is the “public safety exception”. TYet, this court finds no justification for a public safety exception to the Miranda warning in this case. Ias cited in New York v. Quarles 467 U.S. 649, 81 L. Ed. 2d 550, 104 S. Ct. 2626 (1984), the court ruled that a. A police officer can forego the Miranda violations if he or she feels there is imminent danger to the public. However, an unidentified woman answering the door with a known firearm and ex-felon inside does not constitute a public safety exception. There was clearly no threat what so ever. If the exception were to apply to this case, the same could be said for any situation in which there is more than one 'suspect' in the immediate area and the possibility of a lethal weapon exists. Obviously, this road is one the court does not wish to travel.

While this court finds that a clear and definite violation of the defendant’s Miranda rights occurred, this does not resolve the issue completely. Due to the inevitable discovery exception introduced by the petitioner However, the inevitable discovery exception does appear to be relevant to this case and the Miranda violation is insufficient to reverse the decision of the lower court and exonerate the defendant of his charges. This court itself, despite evidence from either side, cannot determine with exact certainty whether or not the inevitable discovery doctrine applies in this case, and therefore, the court must remand the issue back to the lower court in order that a hearing may be conducted to determine this argument’s validity and thus, the outcome of the case.

In Nix v. Williams, 467 U.S. 431, 444, 81 L. Ed. 2d 377, 104 S. Ct. 2501 (1984), the court held that physical evidence along with photographs pertaining to the condition of a murdered girl’s body was admissible despite the fact that the defendant’s testimony was coerced. Even though police had illegally solicited information from Williams, by stating that the missing girl deserved a Christian burial, the court found that the discovery of the body was inevitable through other means, namely an extensive organized search already underway, and therefore, the evidence was still admissible. Clearly, this decision is at the heart of the instant case, in that it determined that “under the inevitable discovery exception, the prosecution is not required to prove the absence of bad faith, since such a requirement would result in withholding from juries relevant and undoubted truth that would have been available to police absent any unlawful police activity.” Although the case at hand does not deal with any massive search parties closing in on the key piece of evidence as did Nix, it does deal with a line of inquiry that may have been sufficient to obtain the evidence in question.

Succinct and straightforward, the petitioner’s argument for inevitable discovery raises questions as to whether the Miranda violation should force the evidence to be discarded in this case. Officer Fox had been told by Ms. O’Donnell, Patane’s ex-girlfriend, that Patane had a gun in his possession, along with a list of people he wanted to kill. Furthermore, Detective Benner, who assisted Fox in the arrest of Patane, had been informed by an ATF agent, through Patane’s parole officer, that Patane was in fact in possession of a firearm. These two sources, both seemingly reliable, suggest that provided more time, Benner would have obtained enough evidence to obtain Patane’s pistol without the Miranda violation. Conversely, the respondent’s contention that Benner’s line of inquiry would not have lead to the discovery of the weapon has little merit, for the evidence of such a claim is limited. However, as mentioned previously, this body itselfwe cannot resolve this problem beyond a reasonable doubtbased on the information we have been provided to a degree which would justify our ruling on this matter. While the exact result of Benner’s investigation can of course only be speculated, this court sees substantial reason to believe that Benner was headed down the path of discovery. Nonetheless, sufficient evidence for determination is still not available to this court and yet, must be obtained.

We therefore remand these proceedings to the lower court so that a hearing may be conducted to determine the literal probability of a separate line of discovery as conducted by Detective Benner. Presumably the lower court will be familiar with the facts of the case, and through interviews and discussions, will be able to determine the admissibility of the pistol in question. While this court can and has determined that a Miranda violation did occur, any further determinations are outside our abilities as a judicial body, therefore Mr. Patane’s legal fate rests in the hands of the able bodied justices from the state of Colorado.