The court, in Miranda, was quick to point out, however, that the decision in that case did not suppose to vitiate the confession as a tool of law enforcement officers in ferretting out criminals. Likewise, volunteered statements of any kind were specifically exempted from the exclusionary rule that was applied to Miranda-type admissions only. Much of the progeny of Miranda addressed itself to just such types of admissions. Oftentimes, the courts dissected the seemingly unitized custodial interrogation requirement of Miranda by turning their decisions of its inapplicability upon the absence of either the "custody" or the "interrogation" aspect
Marvin E. Sable,
Miranda Warnings in Other than Police Custodial Interrogations,
21 Clev. St. L. Rev.
available at https://engagedscholarship.csuohio.edu/clevstlrev/vol21/iss1/15