Law School Case Brief
Brown v. Illinois - 422 U.S. 590, 95 S. Ct. 2254 (1975)
The question whether a confession is the product of a free will must be answered on the facts of each case. No single fact is dispositive. The workings of the human mind are too complex, and the possibilities of misconduct too diverse, to permit protection of the Fourth Amendment to turn on such a talismanic test. The Miranda warnings are an important factor, to be sure, in determining whether the confession is obtained by exploitation of an illegal arrest. But they are not the only factor to be considered. The temporal proximity of the arrest and the confession, the presence of intervening circumstances, and, particularly, the purpose and flagrancy of the official misconduct are all relevant. The voluntariness of the statement is a threshold requirement. And the burden of showing admissibility rests, of course, on the prosecution.
Petitioner, who had been arrested without probable cause and without a warrant, and under circumstances indicating that the arrest was investigatory, made two in-custody inculpatory statements after he had been given the warnings prescribed by Miranda v. Arizona, 384 U. S. 436. Thereafter indicted for murder, petitioner filed a pretrial motion to suppress the statements. The motion was overruled and the statements were used in the trial, which resulted in petitioner's conviction. The State Supreme Court, though recognizing the unlawfulness of petitioner's arrest, held that the statements were admissible on the ground that the giving of the Miranda warnings served to break the causal connection between the illegal arrest and the giving of the statements, and petitioner's act in making the statements was "sufficiently an act of free will to purge the primary taint of the unlawful invasion." Petitioner appealed the judgment.
Are Miranda warnings sufficient to purge the taint of an unconstitutional arrest?
The Supreme Court of the United States reversed the judgment because the state supreme court was in error to conclude that Miranda warnings could always purge the taint of an illegal arrest. The Court held that the Miranda warnings could neither automatically nor by themselves protect an accused's Fourth Amendment rights. Whether a confession was freely given or improperly coerced had to be determined on a case by case basis. The Court held the trial court had to examine factors such as the temporal proximity of the arrest to the confession, the intervening circumstances, and, particularly, the purpose and flagrancy of the official misconduct. The Court also held that the exclusionary rule did not automatically proscribe the use of illegally seized evidence in all proceedings or against all persons, and that Miranda warnings, along with other factors, might permit the admission of such evidence. However, the Court examined the record in light of those factors and concluded that petitioner's statements were inadmissible.
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