tree” doctrine, evidence obtained as an indirect result of illegal state action is also inadmissible. For example, if a defendant is arrested illegally, the government may not use fingerprints taken while the defendant was in custody as evidence. Because police would not have obtained the fingerprints without the illegal arrest, the prints are “fruit of the poisonous tree.” Other examples of evidence inadmissible under this doctrine include: Evidence seized during a search, where the probable cause for the search was illegally obtained evidence A confession made by the defendant, prompted by the admission of illegally obtained evidence against him Evidence derived from information gained in illegal wiretaps However, the "fruit of the poisonous tree" doctrine does not apply to interrogations made without a Miranda warning. Although a confession obtained in violation of Miranda is inadmissible, evidence obtained based on information in the confession is admissible. For example, if police learn the identity of a witness through a confession that violates Miranda, the government may still use the witness's testimony at trial. Limitations Even in a criminal case, the exclusionary rule does not simply bar the introduction of all evidence obtained in violation of the Fourth, Fifth, or Sixth Amendment. In Hudson v. Michigan, Justice Scalia wrote for the U.S. Supreme Court: Limitations on the exclusionary rule have included the following: Private search doctrine: Evidence unlawfully obtained from the defendant by a private person is admissible. The exclusionary rule is designed to protect privacy rights, with the Fourth Amendment applying specifically to government officials. Standing requirement: Evidence can only be suppressed if the illegal search violated the person's own (the person making the court motion) constitutional rights. The exclusionary rule does not apply to privacy rights of a third party. However, there is a narrow exception to this standing requirement, the jus tertii standing exception. Cross-examination: Illegally obtained evidence may be admissible to attack the defendant’s credibility on cross-examination, at least where necessary to prevent gamesmanship. For example, where the defendant affirmatively chooses to make a broad statement denying any narcotics activity, he may not use the exclusionary rule as a shield against attacks on his credibility. However, the government also may not attempt to “smuggle in” excluded evidence on cross-examination by asking broad questions. Inevitable discovery doctrine: Nix v. Williams held that if the evidence obtained in the unlawful search would almost definitely have been found eventually even without said