What US Supreme Court decision established the 'fruit of the poisonous tree' doctrine?

Answer 1

The "fruit of the poisonous tree" is a legal doctrine that prohibits the use in a criminal trial of any evidence that was obtained by means of an illegal arrest, an unauthorized search or from an illegal interrogation by any law enforcement body.

"The fruit of the poisonous tree" is therefore a metaphor. The illegal arrest, search and interrogation would be the poisonous tree. The evidence derived by any of those means would be the fruit from the poisonous tree.

For a good discussion on this doctrine see the link provided below.

Answer 2

The "Fruit of the Poisonous Tree Doctrine" is an extension of the Exclusionary Rule, which holds that evidence obtained via an illegal arrest, an unreasonable search/seizure, and/or a coercive interrogation must be excluded from the trial. The Fruit of the Poisonous Tree Doctrine adds to this in that any evidence obtained with the use of information that was not legally obtained (such as from a coercive interrogation) may also be excluded (along with what caused the "poisonous fruit" (evidence) to be found). For example, a judge may declare that a search was unreasonable, and therefore, under the Fruit of the Poisonous Tree Doctrine, the "fruit," the evidence seized from the unreasonable search (the "Poisonous tree") may be excluded as well, because the search was unlawful/unreasonable, and therefore any evidence obtained from the search is also considered unlawful.

Sources:

1. Fruit of The Poisonous Tree - Cornell University Law School

http://www.law.cornell.edu/wex/fruit_of_the_poisonous_tree

2. Fruit of the Poisonous Tree - The Free (Legal) Dictionary

http://legal-dictionary.thefreedictionary.com/Fruit+of+the+poisoned+tree

Answer 3

The concept was established as a result of the decision in Silverthorne Lumber Co v. US, (1920), but the doctrine was first labeled "the fruit of the poinsonous tree" in Felix Frankfurter's written opinion for Nardone v. US, (1939).

More Information

In Silverthorne, the District Court judge found the company owner, Frederick W. Silverthorne, in contempt of court and ordered him to pay a $250,000 fine for refusing to produce company ledgers and other documents subpoenaed by the US District Attorney for that district.

Federick Silverthorne and his father (unnamed) were arrested in their homes on a single, unspecified charge and taken into custody. While the men were detain, US Marshals from the Department of Justice raided their company and seized without warrant as many business documents as they could find. The DOJ photographed the documents, then returned the originals to the business. Later, they used the information obtained from the photographs to issue a subpoena for the original paperwork.

This was an attempt on the government's part to circumvent the Exclusionary Rule established in Weeks v. US, (1914), that established illegally obtained evidence could not be used to prosecute a defendant.

Justice Oliver Wendell Holmes, Jr. wrote, in the opinion of the Court:

"The essence of a provision forbidding the acquisition of evidence in a certain way is that not merely evidence so acquired shall not be used before the Court, but that it shall not be used at all. Of course, this does not mean that the facts thus obtained become sacred and inaccessible. If knowledge of them is gained from an independent source they may be proved like any others, but the knowledge gained by the Government's own wrong cannot be used by it in the way proposed."

Although the words "fruit of the poisonous tree" do not appear in Holmes' opinion, the doctrine is easily understood as an analogy extending the Exclusionary Rule. The tree represents the illegally obtained evidence; the fruit of the tree is knowledge gained from the evidence. The Court held the government's action was unconstitutional under the Fourth Amendment, and neither the evidence, nor knowledge gained solely from illegally obtained evidence, can be used to prosecute a defendant.

In Nardone, the FBI obtained evidence against the defendant as a result of illegal wire tapping that violated § 605 of the Communications Act of 1934. Nardone's first conviction was overturned and the case remanded for retrial because the tapes obtained from the wiretap had been introduced as direct evidence. While the tapes and transcripts were excluded on retrial, the prosecution introduced evidence the FBI had obtained secondary to the conversations they illegally monitored.

The Supreme Court held that both direct and indirect use of illegally obtained evidence was "inconsistent with ethical standards and destructive of personal liberty."

Justice Frankfurter labeled the concept in this paragraph: "The burden is, of course, on the accused in the first instance to prove to the trial court's satisfaction that wiretapping was unlawfully employed. Once that is established -- as was plainly done here -- the trial judge must give opportunity, however closely confined, to the accused to prove that a substantial portion of the case against him was a fruit of the poisonous tree. This leaves ample opportunity to the Government to convince the trial court that its proof had an independent origin."

The Supreme Court overturned the second conviction on appeal, and again remanded the case to the US District Court.

Case Citations:

Silverthorne Lumber Co v. US, 251 US 385 (1920)

Nardone v. US, 308 US 338 (1939)

Answer 4

There are a number of common law cases that led to the eventual adoption via the US Supreme Court of the Exclusionary Rule or Fruit of the Poison Tree Doctrine. Nix v. Williams allowed for exception to that rule of evidence that would eventually be found (inevitable discovery).

The Exclusionary Rule was passed in the US in 1917 to uphold the Fourth, Fifth, and Sixth Amendments of the US Constitution. Justice Scalia wrote pertinent to Hudson v. Michigan, 547 U.S. 586 (2006) regarding the limited use and scale of the Exclusionary Rule, preventing it from being used indiscriminately.