Taylor v. Alabama
1982 U.S. LEXIS 138, 457 U.S. 687, 73 L. Ed. 2d 314 (1982)
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Rule of Law:
A confession obtained through custodial interrogation following an illegal arrest is inadmissible unless intervening events break the causal connection between the arrest and the confession; the administration of Miranda warnings alone is insufficient to purge the taint of the unlawful arrest.
Facts:
- Following a grocery store robbery in Montgomery, Alabama, police received a tip from an incarcerated individual.
- The informant, who had never provided information before, said he had 'heard' that Omar Taylor was involved but provided no details or source.
- Based solely on this uncorroborated tip, which did not constitute probable cause, two officers arrested Taylor without a warrant.
- At the police station, Taylor was fingerprinted, questioned, and placed in a lineup.
- The victims of the robbery were unable to identify Taylor in the lineup.
- Police informed Taylor that his fingerprints matched prints found on grocery items handled by one of the robbers.
- After a brief, emotional visit with his girlfriend and a male companion, Taylor signed a waiver-of-rights form.
- Immediately following the visit, Taylor executed a written confession to the robbery.
Procedural Posture:
- Omar Taylor was tried for robbery in an Alabama state trial court.
- The trial court overruled Taylor's motion to suppress his confession and he was convicted.
- On appeal by Taylor, the Alabama Court of Criminal Appeals reversed the conviction, holding the confession was the fruit of an illegal arrest.
- The State of Alabama then appealed to the Alabama Supreme Court.
- The Alabama Supreme Court reversed the appellate court's decision, reinstating the conviction.
- The United States Supreme Court granted Taylor's petition for a writ of certiorari to review the decision of the Alabama Supreme Court.
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Issue:
Is a confession made approximately six hours after an illegal arrest, following three Miranda warnings and a brief visit with the suspect's girlfriend, inadmissible as fruit of the illegal arrest?
Opinions:
Majority - Justice Marshall
Yes, the confession is inadmissible. The confession must be suppressed because it was the fruit of an illegal arrest and was not sufficiently an act of free will to purge the primary taint. The Court reasoned that this case is a 'virtual replica' of its precedents in Brown v. Illinois and Dunaway v. New York. The police arrested Taylor without probable cause as an 'investigatory' tactic, hoping something would turn up. The six-hour time lapse between the arrest and confession was not a significant intervening factor, as Taylor remained in continuous custody and was subjected to various police procedures. The Court reiterated that repeated Miranda warnings, while a factor, cannot by themselves cure a Fourth Amendment violation. Furthermore, the short visit with his girlfriend, after which he immediately confessed, was not a meaningful intervening event that could foster free will, and the filing of an arrest warrant based on fingerprints illegally obtained after the arrest could not retroactively validate the confession.
Dissenting - Justice O'Connor
No, the confession should be admissible. The confession was not the fruit of the illegal arrest and should be admissible because sufficient intervening events broke the causal chain. The dissent argued that four factors distinguished this case from Brown and Dunaway: 1) Taylor received three separate Miranda warnings; 2) the police conduct was not flagrant or intimidating; 3) the meeting with his girlfriend and neighbor was a significant intervening event that occurred at Taylor's request, immediately preceding the confession; and 4) Taylor spent most of the six hours alone, not under continuous interrogation. The dissent concluded that the confession was not proximately caused by the illegal arrest, but was a product of Taylor's own decision after consulting with his friends, and thus the state had met its burden to show the taint was purged.
Analysis:
This decision reinforces the exclusionary rule's application to confessions following Fourth Amendment violations, solidifying the precedent set in Brown and Dunaway. It clarifies that a collection of seemingly attenuating factors—passage of time, Miranda warnings, and even brief family contact—will not purge the taint of an illegal arrest if they do not provide a meaningful break in the causal chain. The Court's ruling signals a strong disapproval of 'investigatory arrests' made without probable cause, thereby strengthening the deterrent effect of the exclusionary rule against such police practices. This case underscores the distinction between the voluntariness of a confession for Fifth Amendment purposes and the separate Fourth Amendment analysis required when a confession follows an illegal seizure.
