Sunday, December 22, 2013

Fellers v. United States case brief

Fellers v. United States case brief summary
540 U.S. 519 (2004)

After a jury trial at which petitioner's jailhouse statements were admitted into evidence, petitioner was convicted of conspiring to possess with intent to distribute methamphetamine. Petitioner appealed, arguing that his statements should have been suppressed as fruits of the statements obtained at his home in violation of the Sixth Amendment. The United States Court of Appeals for the Eighth Circuit affirmed. Certiorari was granted.

In refusing to suppress the jailhouse statements, both the trial and appellate courts relied on the rule in Elstad, concluding that the statements were made after petitioner had knowingly and voluntarily waived his Miranda rights.


  • The Supreme Court found that the Court of Appeals erred in holding that the absence of an "interrogation" foreclosed petitioner's claim that the jailhouse statements should have been suppressed as fruits of the statements taken from him at his home. 
  • Clearly, the officers had "deliberately elicited" information from petitioner. 
  • Because the initial discussion took place after petitioner had been indicted, outside the presence of counsel, and in the absence of any waiver of his Sixth Amendment rights, the Court of Appeals erred in holding that the officers' actions did not violate the Sixth Amendment standards established in Massiah and its progeny. 
  • Because it erroneously determined that petitioner was not questioned in violation of Sixth Amendment standards, the Court of Appeals improperly conducted its "fruits" analysis under the Fifth Amendment, specifically, by applying Elstad.

The Supreme Court reversed the judgment. Having not had occasion to decide whether the rationale of Elstad applied when a suspect made incriminating statements after a knowing and voluntary waiver of his right to counsel notwithstanding earlier police questioning in violation of Sixth Amendmentstandards, the case was remanded to the Court of Appeals to address the issue in the first instance.

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