What is the current state of the law on the right to exclude the fruits of a voluntary statement?

justified by its necessity for the protection of the actual right against compelled self-incrimination." (United States v. Patane, supra, 542 U.S. at p. 639.) As the right against self-incrimination is fundamentally a trial right, it is not violated "by negligent or even deliberate failures to provide the suspect with the full panoply of warnings prescribed by Miranda." (Id. at p. 641.) Rather, "violations occur, if at all, only upon the admission of unwarned statements into evidence at trial. And, at that point '[t]he exclusion of unwarned statements ... is a complete sufficient remedy' for any perceived Miranda violation." (Id. at pp. 641-642.) Thus, there is no reason to exclude fruits of unwarned statements. (Patane, at p. 642.) Similarly the court rejected a deterrence argument, noting that admitting nontestimonial fruit of a voluntary statement "presents no risk that a defendant's coerced statements (however defined) will be used against him at a criminal trial." (Id. at p. 643.) Consequently there is no reason to extend the rule to that context.