Facts
- A 14-year-old girl disappeared; investigators learned she had been in a sexual relationship with her 19-year-old half-brother, who had been with 17-year-old Robert Kaupp on the day she disappeared.
- Deputies questioned Kaupp and the half-brother at sheriff’s headquarters; Kaupp cooperated and was allowed to leave.
- After the half-brother failed a polygraph, he confessed to killing the girl and implicated Kaupp.
- Detectives attempted but failed to obtain a warrant to question Kaupp and decided to bring him in to confront him with the confession.
- Around 3 a.m., three uniformed officers and three plainclothes detectives went to Kaupp’s home; after his father let them in, they entered Kaupp’s bedroom, woke him with a flashlight, identified themselves, and said, “we need to go and talk,” to which he replied, “Okay.”
- Officers immediately handcuffed Kaupp and led him outside shoeless, wearing only boxer shorts and a T-shirt, placing him in a patrol car; the record did not show he was told he could refuse to go.
- En route, officers briefly stopped at the location where the victim’s body had been found, then took Kaupp to the sheriff’s headquarters.
- At the station, officers removed the handcuffs, gave Miranda warnings, and interrogated him; after being told about the half-brother’s confession, Kaupp made inculpatory statements but did not confess to murder.
Issues
- Whether Kaupp was seized/arrested under the Fourth Amendment when officers took him from his home in handcuffs at 3 a.m. without a warrant.
- If the seizure was an illegal arrest, whether Kaupp’s later statements were admissible or had to be suppressed as the product of exploitation of the illegality under the attenuation framework of Brown v. Illinois.
Decision
- The Supreme Court (per curiam) vacated and remanded.
- The Court held that Kaupp was arrested before any stationhouse questioning began.
- The arrest was unlawful because it lacked a warrant and the State did not show probable cause.
- The State failed to prove that Kaupp’s statements were sufficiently attenuated from the unlawful arrest; Miranda warnings alone did not purge the taint.
- Kaupp’s statements should have been suppressed.
Legal Principles
- A Fourth Amendment seizure occurs when, under the totality of circumstances, police conduct would communicate to a reasonable person that he is not free to ignore the police and go about his business.
- Factors indicating seizure include multiple officers, physical touching or restraint, coercive language or tone, and circumstances suggesting compliance is compelled.
- Involuntary removal of a suspect from home to a police station for investigative detention requires probable cause or judicial authorization.
- A confession following an illegal arrest is inadmissible if obtained by exploitation of the illegality; attenuation depends on factors including temporal proximity, intervening circumstances, and the purpose and flagrancy of the misconduct.
- Miranda warnings, standing alone, do not necessarily attenuate the taint of an illegal arrest; the prosecution bears the burden to show a sufficient break in the causal chain.
Conclusion
The Court treated the late-night, handcuffed transport of Kaupp from his home to the station as an arrest unsupported by warrant or probable cause and held that the State did not show adequate attenuation to admit the ensuing confession, requiring suppression and remand.