Brown v. Illinois

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

ELI5:

Rule of Law:

Miranda warnings, by themselves, are not sufficient to attenuate the taint of an unconstitutional arrest. For a confession following an illegal arrest to be admissible, the prosecution must show it was an act of free will sufficiently purged of the primary taint, considering the temporal proximity of the arrest and confession, the presence of intervening circumstances, and the purpose and flagrancy of the official misconduct.

Facts:

On May 6, 1968, Roger Corpus was murdered in his Chicago apartment.
Detectives William Nolan and William Lenz obtained Richard Brown's name as an acquaintance of the victim, but Brown was not a suspect.
On May 13, 1968, the two detectives, without a warrant or probable cause, broke into Brown's apartment and searched it.
When Brown arrived home and began climbing the stairs to his apartment, the detectives confronted him at gunpoint and arrested him.
The detectives transported Brown to the police station for questioning about the murder.
Less than two hours after his arrest, police gave Brown Miranda warnings, and he subsequently made an inculpatory statement.
Several hours later, after again receiving Miranda warnings from an Assistant State's Attorney, Brown gave a second, similar inculpatory statement.

Procedural Posture:

Richard Brown was indicted for murder by a Cook County grand jury.
In the Illinois trial court, Brown filed a motion to suppress his two statements, arguing they were the fruit of an illegal arrest.
The trial court denied the motion to suppress.
At trial, the state introduced evidence of both statements, and a jury found Brown guilty of murder.
Brown appealed his conviction to the Supreme Court of Illinois.
The Supreme Court of Illinois affirmed the conviction, finding that although the arrest was unlawful, the subsequent Miranda warnings served to break the causal connection between the arrest and the statements.
The U.S. Supreme Court granted Brown's petition for a writ of certiorari.

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Issue:

Does the issuance of Miranda warnings, by itself, automatically purge the taint of an illegal arrest and make a subsequent confession admissible under the Fourth Amendment?

Opinions:

Majority - Justice Blackmun

No. The issuance of Miranda warnings, by itself, does not automatically purge the taint of an illegal arrest and make a subsequent confession admissible under the Fourth Amendment. While Miranda warnings are a procedural safeguard for Fifth Amendment rights against self-incrimination, they do not remedy Fourth Amendment violations. The exclusionary rule's purpose under the Fourth Amendment is to deter illegal police conduct, and allowing Miranda warnings to be a 'cure-all' would encourage investigatory arrests without probable cause. To determine if a confession is purged of the taint of an illegal arrest, courts must consider several factors: the temporal proximity of the arrest and confession, the presence of intervening circumstances, and the purpose and flagrancy of the official misconduct. Here, Brown's first statement was made less than two hours after the illegal arrest with no intervening events of significance, and the arrest was executed in a manner calculated to cause surprise and fear, indicating an investigatory purpose. The State failed to meet its burden to show the confession was sufficiently an act of free will to be purged of the primary taint.

Concurring - Justice White

The judgment is correct. The Fourth Amendment requires the exclusion of statements obtained as the fruit of an arrest that officers knew or should have known was unconstitutional, despite the issuance of Miranda warnings. The statements in this case fall into that category and were properly excluded.

Concurring in part - Justice Powell

No. The per se rule that Miranda warnings automatically cure an illegal arrest is incorrect, but the case should be remanded for reconsideration by the state courts under the proper standard. The analysis of whether the taint has dissipated should relate to the nature of the Fourth Amendment violation. Flagrantly abusive violations require the clearest indication of attenuation before a confession is admissible, whereas 'technical' violations may be purged by Miranda warnings and a finding of voluntariness. The record in this case is not developed enough to determine, as the majority does, that the arrest was flagrantly improper; it is possible the police reasonably, though erroneously, believed they had probable cause. Therefore, the state courts should be the first to apply the new multi-factor analysis to the facts.

Analysis:

This case clarifies the distinct functions of the Fourth and Fifth Amendments, establishing that compliance with Miranda (a Fifth Amendment protection) does not cure a Fourth Amendment violation. By rejecting a per se rule, the Court created the 'Brown' attenuation factors, a nuanced, multi-factor test that courts must use to determine if a confession is tainted by an illegal arrest. This decision significantly strengthens the Fourth Amendment's exclusionary rule by preventing police from using illegal arrests as an investigatory tool, knowing they can later 'cleanse' the illegality by simply reading a suspect their rights. It forces a case-by-case analysis of the causal connection between police misconduct and the evidence obtained.

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