Brief Fact Summary. Suspect was arrested without probable cause, given Miranda twice, and confessed to murder twice.
Synopsis of Rule of Law. Miranda warnings “by themselves, [do not] assure that . . . statements . . . [are] of sufficient free will as to purge the primary taint of . . . unlawful arrest.”
Issue. Whether a Miranda warning sufficiently breaks the causal chain between an illegal arrest and a confession.
Held. No. Under the rule of Wong Sun, a Miranda warning is “an important factor . . . in determining whether the confession is obtained by exploitation of an illegal arrest.” In the matter at hand, the first statement came “less than two hours” after his illegal arrest, with “no intervening event of significance whatsoever.” The arrest “appear[ed to have] have been calculated to cause surprise, fright, and confusion.”
Concurrence. The concurrence was in part, stating that the justices would have instead remanded rather than reversed.
In Brown, the defendant was arrested without probable cause and without a warrant.View Full Point of Law