Facts of the Case

Michael James Elstad was suspected of committing a burglary and was picked up by police officers in his home. Before officers had given the warnings required by Miranda v. Arizona, Elstad made an incriminating statement. Once at the Sheriff's headquarters, Elstad was advised of his rights. Elstad then voluntarily executed a written confession.

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."