The U.S. Supreme Court’s Seminal Case On The Fruit Of A Poisonous Tree Doctrine: Illegally Acquired Evidence Is Inadmissible
Wong Sun v. United States
U.S Supreme Court
83 S.Ct 407
Decided on January 14, 1963
The U.S. Supreme Court’s Seminal Case On The Fruit Of A Poisonous Tree–Wong Sun: Evidence That Is Illegally Obtained And The Evidence That Is Derived As A Result Of An Initial Illegal Search Is The Fruit Of The Poisonous Tree And Is Inadmissible At Trial.
Summary: Police acquired information on James Wah Toy through a confidential informant. They raided his home and arrested him based on the informant’s information. Toy told Police that he does not sell drugs but knows a person named Johnny Yee who does. Police raided Yee’s home and found a quantity of heroin that was one ounce in weight. Yee stated that a man named Wong Sun, known as “Sea Dog”, brought the heroin to him. Police entered the house of Wong Sun, without a warrant, and searched the home where no narcotics were found.
Issue: Whether evidence illegally obtained, and any derivative evidence obtained therefrom, are admissible at trial where the police conduct a warrantless search in order to obtain evidence and derived evidence.
Holding: The Courts have held that evidence derived from an illegal search are ‘fruits of a poisonous tree’ and are inadmissible at trial. The Court held that a search must be legal at its inception by what it yields. The Court held that the warrantless search in each of the Defendants’ homes constitutes an unreasonable search and seizure under the Fourth Amendment. Therefore, the evidence was illegally acquired and constitutes the ‘fruit of a poisonous tree’ and therefor is inadmissible at trial.
Facts: A confidential informant claimed he purchased heroin from James Wah Toy, and led agents to his house. Agents entered Toy’s home and arrested him without a warrant. The agent had information from a confidential informant that said he was selling. Toy told Police he was not selling heroin but told the Police that he knew a man named Johnny Yee who was. He led police to Johnny Yee’s home.
Agents arrived at Yee’s home and arrested him without a warrant. Yee surrendered to them a quantity of heroin that weighed less than one ounce. Yee told Police the heroin was brought to him by a man named Wong Sun, aka “Sea Dog”. The agents asked Toy where Wong Sun lived, and Toy led police to his home.
The Police raided Wong Suns home without a warrant, they searched the home but no narcotics were ever discovered. Each of the accused made statements to Police. Prior to trial, they argue to suppress their statements stating that they were “fruits of a poisonous tree’, and any evidence derived from that illegal search therefrom are inadmissible at trial.
Legal Analysis: The Exclusionary Rule has traditionally barred any tangible materials or statements obtained as a direct result of an unlawful search. The Fourth Amendment protects citizens from any unlawful searches and seizures, and any evidence that is illegally obtained and/or derived therefrom are “fruits of a poisonous tree” and are inadmissible at trial. The Police violated the Fourth Amendment when they entered Defendants’ homes without a warrant. The Court held that all of the evidence obtained during the warrantless searches, as well as the statements made are “fruits of a poisonous tree’ and are not admissible at trial.