The United States v. Samuel Francis Patane case in 2003 revolved around the issue of whether physical evidence obtained from a suspect who was not read his Miranda rights should be admissible in court. The Supreme Court ruled that such evidence could indeed be used, as long as it was voluntarily given by the defendant and not coerced out of him or her. This decision marked a significant departure from previous rulings which had held that any information gained without reading a suspect their Miranda rights would automatically be excluded from trial proceedings. In this particular case, Samuel Francis Patane's conviction for possession of an illegal firearm was upheld because he willingly gave police officers the gun before they had time to inform him of his right to remain silent.

In the dissenting opinion for United States v. Samuel Francis Patane, Justice David Souter argued that physical evidence obtained as a result of unwarned voluntary statements should be suppressed under Miranda's "fruit of the poisonous tree" doctrine. He contended that Miranda warnings serve to protect an individual’s Fifth Amendment right against self-incrimination and therefore any evidence gained without these warnings is inherently tainted. In his view, allowing such evidence would undermine the purpose of Miranda rights by encouraging police officers to ignore them in order to obtain physical evidence from unwarned but voluntary admissions. Furthermore, he disagreed with the majority's distinction between testimonial and non-testimonial evidence in this context, arguing it was inconsistent with previous case law and could lead to confusion about what constitutes admissible or suppressible post-arrest statements.