Oregon v. Elstad

E238771

Miranda rights case United States Supreme Court case criminal procedure case

Oregon v. Elstad is a 1985 U.S. Supreme Court decision holding that a suspect’s later, properly Mirandized confession can be admissible even if an earlier unwarned statement was obtained in violation of Miranda.

Try in SPARQL Jump to: Surface forms Disambiguation Statements Elicitation Referenced by

All labels observed (2)

Label	Occurrences
Oregon v. Elstad canonical	5
Oregon v. Elstad, 470 U.S. 298 (1985)	2

How this entity was disambiguated

This entity first appeared as the object of triple T2151518 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.

NED1 Entity disambiguation (via context triple) gpt-5-mini-2025-08-07

Target entity: Oregon v. Elstad
Context triple: [Dickerson v. United States, relatedCase, Oregon v. Elstad]

A. De Jonge v. Oregon
De Jonge v. Oregon is a 1937 U.S. Supreme Court case that held the right to peaceful assembly is a fundamental liberty protected by the Due Process Clause of the Fourteenth Amendment and thus applies to the states.
B. Strickland v. Washington
Strickland v. Washington is a landmark 1984 U.S. Supreme Court case that established the two-pronged test for determining when a criminal defendant’s right to effective assistance of counsel has been violated.
C. Virginia v. Black
Virginia v. Black is a 2003 U.S. Supreme Court case that upheld a ban on cross burning carried out with intent to intimidate while clarifying the limits of First Amendment protection for hate speech and symbolic expression.
D. Eisenstadt v. Baird
Eisenstadt v. Baird is a landmark 1972 U.S. Supreme Court decision that extended the right to possess and use contraceptives to unmarried individuals, significantly advancing privacy and equal protection jurisprudence.
E. Crawford v. Washington
Crawford v. Washington is a landmark 2004 U.S. Supreme Court decision that reshaped Confrontation Clause jurisprudence by holding that testimonial hearsay is inadmissible against a criminal defendant unless the witness is unavailable and there was a prior opportunity for cross-examination.
F. None of above. chosen
G. Unsure - the case is ambiguous/there is not enough information to decide.

NED2 Entity disambiguation (via description) gpt-5-mini-2025-08-07

Target entity: Oregon v. Elstad
Target entity description: Oregon v. Elstad is a 1985 U.S. Supreme Court decision holding that a suspect’s later, properly Mirandized confession can be admissible even if an earlier unwarned statement was obtained in violation of Miranda.

A. De Jonge v. Oregon
De Jonge v. Oregon is a 1937 U.S. Supreme Court case that held the right to peaceful assembly is a fundamental liberty protected by the Due Process Clause of the Fourteenth Amendment and thus applies to the states.
B. Strickland v. Washington
Strickland v. Washington is a landmark 1984 U.S. Supreme Court case that established the two-pronged test for determining when a criminal defendant’s right to effective assistance of counsel has been violated.
C. Virginia v. Black
Virginia v. Black is a 2003 U.S. Supreme Court case that upheld a ban on cross burning carried out with intent to intimidate while clarifying the limits of First Amendment protection for hate speech and symbolic expression.
D. Eisenstadt v. Baird
Eisenstadt v. Baird is a landmark 1972 U.S. Supreme Court decision that extended the right to possess and use contraceptives to unmarried individuals, significantly advancing privacy and equal protection jurisprudence.
E. Crawford v. Washington
Crawford v. Washington is a landmark 2004 U.S. Supreme Court decision that reshaped Confrontation Clause jurisprudence by holding that testimonial hearsay is inadmissible against a criminal defendant unless the witness is unavailable and there was a prior opportunity for cross-examination.
F. None of above. chosen

Statements (48)

Predicate	Object
instanceOf	Miranda rights case ⓘ United States Supreme Court case ⓘ criminal procedure case ⓘ
areaOfLaw	constitutional law ⓘ criminal procedure ⓘ self-incrimination ⓘ
arguedDate	1984-10-31 ⓘ
citation	470 U.S. 298 ⓘ
citationStyle	Oregon v. Elstad, 470 U.S. 298 (1985) ⓘ linked to: Oregon v. Elstad
constitutionalProvision	Fifth Amendment to the United States Constitution ⓘ Miranda v. Arizona doctrine ⓘ linked to: Miranda v. Arizona
court	Supreme Court of the United States ⓘ
decisionDate	1985-03-04 ⓘ
dissentingOpinionBy	Justice Thurgood Marshall ⓘ linked to: Thurgood Marshall
distinguishedFrom	Miranda v. Arizona ⓘ Wong Sun v. United States ⓘ
docketNumber	83-773 ⓘ
doctrine	two-step interrogation rule regarding unwarned and warned statements ⓘ
fullCaseName	Oregon v. Elstad ⓘ
holding	A simple failure to administer Miranda warnings, without actual coercion or improper tactics, does not taint a subsequent Mirandized confession under the fruit of the poisonous tree doctrine ⓘ A suspect’s later, voluntary confession made after proper Miranda warnings is not automatically inadmissible solely because it followed an earlier unwarned but voluntary statement ⓘ The Fifth Amendment does not require suppression of a subsequent voluntary statement made after Miranda warnings solely because the police earlier obtained an unwarned admission ⓘ
impact	established that a subsequent Mirandized confession can be admissible despite a prior Miranda violation if voluntary ⓘ narrowed the exclusionary rule for unwarned but voluntary statements under Miranda ⓘ
joinedByInDissent	Justice Harry A. Blackmun ⓘ linked to: Harry A. Blackmun
joinedByInMajority	Chief Justice Warren E. Burger ⓘ linked to: Warren E. Burger Justice Byron R. White ⓘ linked to: Byron R. White Justice John Paul Stevens ⓘ linked to: John Paul Stevens Justice Lewis F. Powell Jr. ⓘ linked to: Lewis F. Powell Jr. Justice William H. Rehnquist ⓘ linked to: William H. Rehnquist Justice William J. Brennan Jr. ⓘ linked to: William J. Brennan Jr.
jurisdiction	United States ⓘ linked to: United States of America
keyConcept	Fifth Amendment privilege against self-incrimination ⓘ linked to: Fifth Amendment to the United States Constitution Miranda warnings ⓘ linked to: Miranda v. Arizona fruit of the poisonous tree ⓘ voluntariness of confessions ⓘ
laterInterpretedBy	Missouri v. Seibert ⓘ
legalIssue	admissibility of a Mirandized confession following an earlier unwarned statement ⓘ
majorityOpinionBy	Justice Sandra Day O'Connor ⓘ linked to: Sandra Day O’Connor
originatingCourt	Oregon state courts ⓘ linked to: Oregon Judicial Department
overrulesOrLimits	broad application of the fruit of the poisonous tree doctrine to mere Miranda violations ⓘ
page	298 ⓘ
party	Michael James Elstad ⓘ State of Oregon ⓘ linked to: Oregon
reporter	United States Reports ⓘ
result	conviction affirmed ⓘ
volume	470 ⓘ
yearDecided	1985 ⓘ

How these facts were elicited

Referenced by (7)

Full triples — surface form annotated when it differs from this entity's canonical label.

Dickerson v. United States → relatedCase → Oregon v. Elstad ⓘ

Oregon v. Elstad → fullCaseName → Oregon v. Elstad ⓘ

Oregon v. Elstad → citationStyle → Oregon v. Elstad, 470 U.S. 298 (1985) ⓘ

linked to: Oregon v. Elstad

Michigan v. Tucker → citedBy → Oregon v. Elstad ⓘ

Missouri v. Seibert → relatedCase → Oregon v. Elstad ⓘ

Michael James Elstad → defendantIn → Oregon v. Elstad ⓘ

Michael James Elstad → caseHeWasInCitation → Oregon v. Elstad, 470 U.S. 298 (1985) ⓘ