State of Tennessee v. Timothy Walton

Summary

The Tennessee Supreme Court held that Timothy Walton was both in custody and subjected to custodial interrogation in violation of Miranda when Officer Johnson asked follow-up questions to Walton's volunteered statements after having reason to believe the answers would reveal stolen property; those interrogation-derived statements are therefore suppressed. The Court nonetheless refused to suppress the physical evidence Walton led officers to recover, announcing that non-testimonial fruits of a mere failure to give Miranda warnings are admissible absent actual coercion or a dishonored invocation of rights, under both the Fifth Amendment and Article I, section 9 of the Tennessee Constitution, and rejecting the argument that Dickerson converted Miranda's procedures into per se constitutional commands. Because the certified suppression question proved not dispositive but was addressed under special circumstances as an issue of first impression, the Court affirmed the intermediate court in part and reversed it in part, remanding so Walton—who pleaded guilty expecting his statements to be admissible—may withdraw his plea. Justice Birch, concurring in part and dissenting in part, agreed the statements must be suppressed but would also have suppressed the physical evidence derived from the violation.