holding that an inculpatory statement given as a result of a Fourth Amendment violation such as an unconstitutional arrest is excludable even if the defendant subsequently receives his Mi randa warnings, unless the prosecution can show that the circumstances “make the [statement] sufficiently a product of free will [to] break, for Fourth Amendment purposes, the causal connection between the illegality and the confession”
How later courts described this case
- holding that an inculpatory statement given as a result of a Fourth Amendment violation such as an unconstitutional arrest is excludable even if the defendant subsequently receives his Mi randa warnings, unless the prosecution can show that the circumstances “make the [statement] sufficiently a product of free will [to] break, for Fourth Amendment purposes, the causal connection between the illegality and the confession”
- holding that an officer’s erroneous belief that he was arresting the correct person was not sufficient misconduct to require suppression of post-arrest statements and bullets obtained from arrestee’s person; an “unreasonable mistake of fact ... does not constitute the type of blatantly unconstitutional or flagrant behavior condemned in Brown”
- stating that to ensure that a violation of the Fourth Amendment "has not been unduly exploited" to obtain a confession, the prosecutor must show "not merely that the statement meets the Fifth Amendment standard of voluntariness but that it be sufficiently an act of free will to purge the primary taint" (internal quotation marks omitted)
- finding, in contrast, no attenuation when the actions of law enforcement “had a quality of purposefulness” and the detectives “repeatedly acknowledged, in their testimony, that the purpose of their actions was ‘for investigation’ or for ‘questioning’ ” indicating an “expedition for evidence in the hope that something might turn up”
Written by the judges who cited it.
Distinguished
Distinguished by Castillo v. People, 59 V.I. 240 (2013)
Having concluded that the April 12, 2007 arrest was lawful, the Brown factors are inapplicable to Castillo’s statements that followed thereafter.
Distinguished by State v. Sarria, 2012 Fla. App. LEXIS 15323 (2012)
Because there was no illegal arrest, the trial court’s analysis under Brown v. Illinois, 422 U.S. 590, 95 S.Ct. 2254, 45 L.Ed.2d 416 (1975), was inapposite.
Distinguished by State v. Eserjose, 259 P.3d 172 (2011)
Brown and its progeny are distinguishable from this case since the violation is qualitatively different: here the deputies had probable cause to arrest.
Distinguished by United States v. Granados, 587 F. Supp. 2d 1112 (2008)
422 U.S. 590, 95 S.Ct. 2254, 45 L.Ed.2d 416 (1975) was distinguishable because the incriminating statements in that case were taken after an arrest without probable cause. 495 U.S. at 18-19, 110 S.Ct. 1640.
The opinion
*606 Mr. Justice White,
concurring in the judgment.
Insofar as the Court holds (1) that despite Miranda warnings the Fourth and Fourteenth Amendments require the exclusion from evidence of statements obtained as the fruit of an arrest which the arresting officers knew or should have known was without probable cause and unconstitutional, and (2) that the statements obtained in this case were in this category, I am in agreement and therefore concur in the judgment.