## Facts

- Chicago detectives arrested Richard Brown in his apartment while investigating the murder of Roger Corpus.
- The arrest was warrantless and made without probable cause; it was treated as investigatory rather than based on evidence supporting arrest.
- After being taken to the station, Brown received Miranda warnings and was interrogated.
- Brown gave a first inculpatory statement less than two hours after the illegal arrest and a second statement about seven hours later after receiving Miranda warnings again.
- The statements were admitted at trial and were central evidence supporting Brown’s murder conviction.
- The Illinois Supreme Court accepted the arrest was unlawful but held the statements admissible because Miranda warnings were deemed sufficient to purge the taint of the illegal arrest.

## Issues

1. Whether Miranda warnings, by themselves, are sufficient to break the causal connection between an illegal arrest and a later confession for Fourth Amendment exclusionary-rule purposes.
2. What standards govern whether a confession following an unlawful arrest is admissible as sufficiently attenuated from the illegality.

## Decision

- The Supreme Court reversed and remanded.
- The Court rejected a per se rule that Miranda warnings alone purge the taint of an illegal arrest.
- The Court held the State did not meet its burden to show Brown’s statements were admissible under the Fourth Amendment attenuation doctrine.
- Applying attenuation considerations, the Court concluded the confessions were obtained by exploitation of the unlawful arrest and had to be suppressed.

## Legal Principles

- A confession may be voluntary under the Fifth Amendment and still be inadmissible as the fruit of an unlawful arrest under the Fourth Amendment.
- Miranda warnings are a relevant consideration in attenuation analysis but are not dispositive and do not automatically cure an illegal arrest.
- The admissibility question is whether the statement was obtained by exploitation of the illegal arrest or by means sufficiently distinguishable to purge the primary taint.
- Courts evaluate attenuation case-by-case, commonly considering: (1) temporal proximity between arrest and statement, (2) intervening circumstances, and (3) the purpose and flagrancy of the official misconduct.
- The prosecution bears the burden of proving admissibility of in-custody statements following an illegal arrest.

## Conclusion

The Court held that Miranda warnings do not, standing alone, dissipate the Fourth Amendment taint of a warrantless, unsupported arrest; confessions obtained after such an arrest must be excluded unless the State proves attenuation under factors such as time, intervening events, and the purpose and flagrancy of police misconduct.


Brown v. Illinois, 422 U.S. 590 (1975)