In Brown v. Illinois, 422 U.S. 590 (1975), the Supreme Court held that Miranda warnings, standing alone, do not purge the taint of an unconstitutional arrest. A confession obtained after an illegal seizure can still be excluded under the Fourth Amendment, and the prosecution carries the burden of showing the statement was sufficiently separated from the police misconduct to be admissible.1Law Resource. 422 U.S. 590
What Happened to Richard Brown
Chicago detectives investigating the murder of Roger Corpus broke into Richard Brown’s apartment without a search warrant or an arrest warrant. They searched the place, waited for him, and confronted him at gunpoint when he came home. They had no probable cause to arrest him.1Law Resource. 422 U.S. 590
At the station, officers read Brown his Miranda rights before questioning him. He made two statements tying himself to the killing. Both were used at trial, and he was convicted of murder.1Law Resource. 422 U.S. 590
The Reasoning the Supreme Court Rejected
Brown moved to suppress the statements as fruit of the illegal arrest. The trial judge denied the motion, and the Illinois Supreme Court affirmed the conviction. Its reasoning was straightforward: once officers gave Miranda warnings, any statement that followed was a voluntary choice, and that voluntariness broke the causal chain back to the unlawful arrest. In effect, the state court treated a Fifth Amendment warning as a cure for a Fourth Amendment violation.1Law Resource. 422 U.S. 590
What the Supreme Court Held
The Supreme Court reversed. The Fourth and Fifth Amendments protect different interests, and one cannot be traded for the other. The Fifth Amendment guards against compelled self-incrimination; the Fourth Amendment restrains unreasonable searches and seizures. Treating Miranda warnings as an automatic fix would give police a strong incentive to skip warrants and probable cause, knowing they could paper over the illegality once the suspect was in the interrogation room.1Law Resource. 422 U.S. 590
Miranda compliance is part of the analysis, not the end of it. The prosecution must show that a confession following an illegal arrest was not the product of that arrest, and courts must look at the facts of each encounter to decide whether the statement is too closely tied to the constitutional violation to be admitted.1Law Resource. 422 U.S. 590
The exclusionary rule ordinarily blocks the government from using evidence obtained through unconstitutional means. It is not absolute, and may give way where evidence would have been discovered inevitably by lawful means.2Law Resource. 467 U.S. 431
The Brown Factors for Attenuation
The Court set out the framework judges still use to decide whether a confession is sufficiently attenuated from an illegal arrest. The statement must first be voluntary. If it is, courts weigh several additional factors:3Law Resource. 442 U.S. 2001Law Resource. 422 U.S. 590
- The time that passed between the arrest and the statement
- Any significant intervening events
- The purpose and flagrancy of the police misconduct
- Whether Miranda warnings were given
Time Between Arrest and Confession
Brown gave his first statement within two hours of being taken into custody. The Court treated that short interval as a sign that the pressure of the illegal arrest had not dissipated.4Federal Reporter. 704 F.2d 701
Intervening Circumstances
Courts look for events that break the link between the illegal seizure and the statement, such as release from custody or an appearance before a judge. The weight of any such event depends on the specific facts. Brown remained in continuous police custody with no meaningful break, so nothing intervened to separate the confession from the arrest.5Law Resource. 371 U.S. 471
Purpose and Flagrancy of Police Conduct
Detectives conceded they had arrested Brown specifically to question him, without a warrant and without probable cause. Because officers acted with the deliberate goal of conducting an investigatory arrest they knew they could not legally make, the connection between the arrest and the confession was too strong to overlook.1Law Resource. 422 U.S. 590
Miranda Warnings
Brown was warned before he spoke. That fact matters, but under this framework it is one input among several, not a shortcut past the Fourth Amendment.1Law Resource. 422 U.S. 590