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Brown v. Illinois

Supreme Court of the United States · 1975 · Criminal Procedure

Criminal ProcedureFourth AmendmentFifth AmendmentExclusionary RuleConfessionsillegal arrestprobable causewarrantless arrest

Facts

Chicago detectives broke into Brown's apartment, searched it, and arrested him without a warrant and without probable cause for the purpose of questioning him about a murder investigation. After being taken to the station, Brown received full Miranda warnings and, less than two hours after the arrest, gave a signed inculpatory statement. Later that night, after further custody and additional Miranda warnings, he gave a second inculpatory statement to an assistant state's attorney. Both statements were introduced at his murder trial.

Issue

Whether inculpatory statements made after an arrest without probable cause must be excluded as the fruit of the illegal arrest, or whether the giving of Miranda warnings alone is sufficient to break the causal connection and render the statements admissible.

Rule

Miranda warnings, standing alone and per se, do not automatically purge the taint of an unconstitutional arrest for Fourth Amendment purposes. To determine whether a statement obtained after an illegal arrest is admissible under Wong Sun, a court must consider whether the statement was sufficiently an act of free will to purge the primary taint, taking into account voluntariness as a threshold requirement, the temporal proximity of arrest and confession, the presence of intervening circumstances, and particularly the purpose and flagrancy of the official misconduct; the prosecution bears the burden of showing admissibility.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Milwaukee, detectives arrested Omar Vega outside his apartment without a warrant and without probable cause because they wanted to question him about a warehouse arson. Forty-five minutes later at the station, after full Miranda warnings and a signed waiver, Omar gave a detailed incriminating statement; nothing else of significance occurred in between.

Is Omar's statement most likely admissible?

Explanation. The governing rule is that Miranda warnings, standing alone, do not per se attenuate the taint of an unconstitutional arrest. Voluntariness is only a threshold requirement. The court must also consider temporal proximity, intervening circumstances, and especially the purpose and flagrancy of the misconduct. Here the confession followed quickly after the illegal arrest and no meaningful intervening event occurred, so the statement would likely be suppressed.