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The United States prosecuted Jerri C. Lewis for bank robbery after FBI Special Agent Michael E. Degnan identified her from photographs taken during a robbery on October 9, 1986. Degnan recognized Lewis from his prior work as case agent in an earlier bank robbery prosecution that resulted in her conviction, and Lewis was arrested on October 20, 1986. On October 21, 1986, Degnan and Special Agent Fujita visited the prison ward of San Francisco General Hospital to interview Lewis, where they learned from the hall nurse that she had just returned from surgery to remove an abscess on her left shoulder caused by narcotics injection. The agents spoke with her for approximately two minutes, during which Degnan asked whether she was going to come clean and Lewis replied that she would, and when asked how many robberies they would discuss she responded that the number was three; the agents then told her they would return the next day. The agents returned on October 22, 1986, and the hall nurse informed them that Lewis was alert and not under any medication that would affect her ability to be interviewed. Lewis appeared alert, looked much better than the day before, and stated she was feeling okay. Agent Fujita gave her a copy of the FO 395 Advice of Rights and Waiver Form, read it to her, and she signed it to indicate waiver of counsel while acknowledging that no promises, threats, pressure, or coercion had been used against her. During the interview Lewis admitted committing three robberies and commented on photographs of the crimes shown to her. Lewis moved to suppress both statements, arguing in her memorandum that the October 21 statement was involuntary because she was a heroin addict suffering from drug withdrawal and was questioned hours after awakening from general anesthesia, and that the October 22 statement was obtained through exploitation of the prior admission. At the December 18, 1986 hearing on the motion, the district court stated that the first statement was not knowing and voluntary before hearing argument from counsel, relying on the judge's personal experience coming out of general anesthesia, even though the factual issues had been submitted on declarations filed by each party and the court stated it was resolving controverted facts in favor of the government while discounting the defendant's claims. The government appealed the suppression order. The appeal was submitted on the declarations, with the district court having accepted as true the facts set forth in Degnan's declaration and having rejected all contradictory statements in Lewis's declaration as untrue.

In December 1981, the home of Mr. and Mrs. Gilbert Gross in Salem, Oregon, was burglarized, with art objects and furnishings valued at $150,000 missing. A witness implicated 18-year-old Michael James Elstad, a neighbor and friend of the Grosses' teenage son. Officers Burke and McAllister arrived at Elstad's home with an arrest warrant. Elstad's mother led them to his bedroom where he lay on his bed. The officers asked him to get dressed and accompany them to the living room. Officer Burke asked Elstad if he knew why they were there and if he knew the Gross family. Burke then stated he felt Elstad was involved in the burglary, and Elstad responded, "Yes, I was there." The officers arrested Elstad and transported him to the Polk County Sheriff's office. Approximately one hour later, the officers joined Elstad in an interrogation room. Detective McAllister advised Elstad of his Miranda rights from a printed card. Elstad indicated he understood his rights and wished to speak with the officers. He then provided a full statement explaining that he had known the Gross family was out of town, had been paid to lead acquaintances to the residence, and showed them how to enter through a defective sliding glass door. The statement was typed, reviewed, corrected, initialed, and signed by Elstad and the officers. Elstad added a sentence about receiving a bag of grass. Elstad was charged with first-degree burglary. He waived his right to a jury trial. Before trial, he moved to suppress both his oral statement at home and his signed confession at the station. The trial court suppressed the initial statement but admitted the written confession, finding it was given freely, voluntarily, and knowingly after a valid waiver. Elstad was convicted and sentenced to five years imprisonment plus $18,000 in restitution. The Oregon Court of Appeals reversed the conviction. The court held that the second statement was inadmissible as the fruit of the poisonous tree because the connection between the inadmissible first statement and the written confession was not sufficiently attenuated. The Oregon Supreme Court declined review. The United States Supreme Court granted certiorari to consider the question whether the Self-Incrimination Clause requires suppression of a confession made after proper Miranda warnings and a valid waiver solely because the police had obtained an earlier voluntary but unwarned admission.

On March 26, 1971, the proprietor of a pizza parlor in Rochester, New York, was killed during an attempted robbery. On August 10, 1971, Detective Anthony Fantigrossi learned of a possible lead implicating petitioner Irving Dunaway in the crime from an informant. Fantigrossi questioned a jail inmate but obtained no information sufficient to secure a warrant for Dunaway's arrest. Nevertheless, on the morning of August 11, 1971, three detectives located Dunaway at a neighbor's house and took him into custody. Although not told he was under arrest, Dunaway would have been physically restrained if he had attempted to leave. He was driven to police headquarters in a police car and placed in an interrogation room. After receiving Miranda warnings, Dunaway waived his right to counsel and made statements and drew sketches that incriminated him in the crime. He was then formally arrested and charged with murder and attempted robbery. Dunaway's motion to suppress the statements and sketches was denied at trial, and he was convicted by a jury. Following initial affirmances and a remand from the Supreme Court in light of Brown v. Illinois, the County Court found the detention illegal and granted the suppression motion, but the Appellate Division reversed that determination. The New York Court of Appeals dismissed Dunaway's application for leave to appeal.

In January 1964, fourteen-year-old Pamela Mason disappeared from her home in Manchester, New Hampshire, during a heavy snowstorm after receiving a telephone call about a babysitting job. Her body was discovered eight days later beside a major highway, prompting a massive police investigation. On January 28, officers visited Edward Coolidge at his home after learning he had been absent on the night of the disappearance. Coolidge produced three guns for inspection and agreed to take a lie-detector test. On February 2, while Coolidge was at the police station undergoing the test, two plainclothes officers arrived at his house and spoke with his wife. Mrs. Coolidge provided four guns belonging to her husband and some clothing she believed he might have worn on the night in question. Coolidge was held overnight on an unrelated charge but released the next day. Over the following two and a half weeks, the State accumulated evidence implicating Coolidge. On February 19, the results of the investigation were presented at a meeting between the police officers working on the case and the State Attorney General, who had personally taken charge of all police activities relating to the murder, and was later to serve as chief prosecutor at the trial. Coolidge was arrested at his home that day. His 1951 Pontiac automobile parked in the driveway was seized and towed to the police station two and a half hours later. The Pontiac was searched and vacuumed on February 21, again in January 1965, and a third time in April 1965. At Coolidge's subsequent jury trial for murder, vacuum sweepings from the car were introduced into evidence. One of the guns taken from the home was also introduced. Vacuum sweepings from the clothing were introduced into evidence. The New Hampshire Supreme Court affirmed the conviction after upholding the admissibility of the evidence, and the United States Supreme Court granted certiorari.