Oregon v. Elstad
E238771
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.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Oregon v. Elstad canonical | 3 |
| Oregon v. Elstad, 470 U.S. 298 (1985) | 1 |
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
ⓘ
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
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Oregon v. Elstad Description of subject: 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.
Referenced by (4)
Full triples — surface form annotated when it differs from this entity's canonical label.
linked to: Oregon v. Elstad