People v.ваем, 41 N.Y.2d 928 (1977)

Evidence obtained as a result of a voluntary statement, even if the statement itself is inadmissible due to Miranda violations, is admissible, and a defendant lacks standing to assert the Miranda rights of another person.

Summary

The New York Court of Appeals held that testimony from witnesses whose names were provided by the defendant during a police interrogation, even if the defendant’s own statements were inadmissible due to Miranda violations, was admissible. Additionally, a pistol seized pursuant to a search warrant based on information from both the defendant and another individual was admissible, as the defendant lacked standing to assert the other individual’s Miranda rights. The court also noted that an assertion of error regarding testimony about the defendant’s admission to other killings was not preserved for review due to a lack of timely objection.

Facts

The defendant, ваем, made statements to the police during an interrogation. These statements were deemed voluntary. During the interrogation, the defendant provided the names of certain witnesses. A search warrant was issued based on information provided by both the defendant and another individual named Russell, leading to the seizure of the defendant’s pistol. The defendant’s statements were excluded at trial due to the police’s failure to provide Miranda warnings.

Procedural History

The case was tried, and the defendant was convicted. The Appellate Division affirmed the conviction. The case then went to the New York Court of Appeals.

Issue(s)

1. Whether the testimony of witnesses, whose names the defendant furnished during an interrogation where Miranda warnings were not properly given, is admissible.
2. Whether a pistol seized pursuant to a search warrant issued on information supplied by another individual, Russell, as well as the defendant is admissible, when Russell was not given Miranda warnings.
3. Whether the defendant’s assertion of error regarding the receipt of testimony that he had admitted to other killings was preserved for review.

Holding

1. Yes, because the defendant’s statements were voluntary, and the derivative evidence rule does not automatically exclude evidence obtained as a result of a voluntary statement even if the statement itself is inadmissible due to Miranda violations.
2. Yes, because the defendant lacked standing to complain about the failure of the police to give Miranda warnings to Russell.
3. No, because no timely objection was raised, and the issue was not preserved for review.

Court’s Reasoning

The Court of Appeals relied on the Supreme Court’s decision in Michigan v. Tucker, which held that the exclusionary rule does not bar the admission of testimony from a witness whose identity was revealed by the defendant during questioning without full Miranda warnings, where the questioning was voluntary. The court reasoned that the exclusion of the defendant’s own statements was sufficient to protect his Fifth Amendment rights. The court distinguished the case from situations where the police conduct is coercive or the derivative evidence is directly obtained in violation of the defendant’s rights. Regarding the pistol, the court cited Alderman v. United States and Jones v. United States, stating that a defendant lacks standing to assert the constitutional rights of another person. Therefore, the defendant could not claim that the pistol should be excluded because Russell was not given Miranda warnings. Finally, because the defendant did not object to the testimony regarding his admission to other killings during the trial, the court found that the issue was not preserved for appellate review. The court emphasized the importance of timely objections to allow the trial court to correct any errors.