Brown v. Illinois

Brown v. Illinois Case Brief

United States Supreme Court
422 U.S. 590 (1975)

ISSUE: Did Miranda warnings sufficiently attenuate the taint of an illegal arrest in order from them to be admissible into evidence?
HOLDING: No.
FACTS:
  • Detectives Nolan and Lenz broke into Brown's apartment and searched it after they had been given Brown's name as part of a murder investigation
  • Detectives waited for D to arrive and then arrested him at gunpoint when he arrived and took him to the police station
  • D was Mirandized and then agreed to talk about the murder
    • Questioning resulted in a 2-page statement, which D refused to sign
    • Brown said that he was ordered by one Claggett to bind V's hands and feet, and then Claggett shot V
  • Detectives took D on a ride to look for Claggett and found and arrested Claggett later that night
  • Brown was then Mirandized and interrogated again by an Asst. State's Atty, and Brown made another statement
PROCEDURAL HISTORY:
  • Brown and Claggett were indicted
  • D moved to suppress his statements -- denied
  • Jury convicted D of murder, and Ill. Sup. Ct. affirmed conviction
    • Sup. Ct. adopted at test that Miranda warnings made a statement following illegal police activity per se an act of free will as to purge the primary taint as required by Wong Sun 
REASONING:
  • Miranda warnings insufficient: If Miranda warnings by themselves were held to attenuate the taint of an unconstitutional arrest, regardless of how wanton and purposeful the 4th Amdt. violation, the effect of the exclusionary rule would be substantially diluted
    • Miranda warnings, and the exclusion of the confession made without them, do not alone sufficiently deter a 4th Amdt. violation
    • Policies underlying Exclusionary Rule are different between 4th & 5th Amdts.
    • Miranda warnings have never been held to be a means of remedying or deterring 4th Amdt. violations
  • Wong Sun "sufficiently an act of free will" test: Question whether a confession is the product of a free will under Wong Sun must be answered on the facts of each case
    • Miranda warnings are not dispositive but are an important factor
    • Also consider temporal proximity between the arrest and the confession, presence of intervening circumstances, and the purpose and flagrancy of the official misconduct
  • Not admissible under Wong Sun: State failed to sustain its burden of showing that the statements were admissible under Wong Sun 
    • Separated from illegal arrest by less than 2 hours
    • No intervening event of significance
    • Illegality had a quality of purposefulness
COMMENTS:

OTHER CASES:
  • United States v. Ceccolini: The illegality which led to the the discovery of a witness very often will not play any meaningful part in the witness's willingness to testify
    • Witnesses often come forward of their own volition in order to testify
    • A closer, more direct link between the illegality and the live-witness testimony is required in order to exclude it
    • Holding: A live witness's testimony is always attenuated from the initial 4th Amdt. violation that resulted in the discovery of that witness (seeWong Sun)
      • Intervening act of free will attenuates the 4th Amdt. violation
  • New York v. Harris: Where the police have PC to arrest a suspect, the exclusionary rule does not bar the State's use of a statement made by a D outside his home, even though the statement is taken after an warrantless arrest in his home (and thus illegal)
    • Statement inside the house is inadmissible b/cMiranda warnings do not dissipate the taint perBrown of the warrantless entry into the home (Payton)
    • Statement outside the house is admissible b/c the existence of PC makes the continued custody lawful (see Watson)
      • Payton rule requiring a warrant to arrest in the home was designed to protect the integrity of the home, not incriminating statements
      • No causal connection between an illegal entry and a voluntary statement made outside the home

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