Brown v. Illinois, 422 U.S. 590 (1975), was a case in which the Supreme Court of the United States held that the Fourth Amendment's protection against the introduction of evidence obtained in an illegal arrest is not attenuated by reading the defendant their Miranda Rights.
People v. Brown, 56 Ill. 2d 312, 307 N.E.2d 356 (1974); cert. granted, 419U.S. 894 (1974).
Holding
Miranda warnings do not automatically purge the taint of an unlawful arrest. A court must examine the time between the arrest of a suspect and the suspect's confession, any intervening circumstances, and the purpose and the flagrancy of official misconduct when determining if the confession of a properly Mirandized but illegally arrested suspect may be admitted as evidence.
On May 13, 1968, Richard Brown was arrested outside of his Chicago, IL. apartment by two members of the Chicago Police.[1] The two officers, William Nolan and William Lenz, entered Mr. Brown's apartment without probable cause later testifying that they had entered to question Brown concerning the death of Roger Corpus, who had been killed a week prior.[1]
Following his arrest, Mr. Brown was taken to a police station for interrogation; prior to beginning his interrogation, Mr. Brown was read his Miranda Rights.[2] During interrogation Mr. Brown produced a two-page written document acknowledging his role in the killing of Roger Corpus.[3] Mr. Brown would later give another statement to the Assistant State's Attorney assigned to the case again acknowledging his role in Mr. Corpus' death but also containing a number of factual inaccuracies.[4] Both statements would later be introduced at trial, ultimately resulting in Mr. Brown's conviction for the murder of Roger Corpus.[5]
On review, the Illinois Supreme Court held that by giving Mr. Brown Miranda Warnings, the causal chain between the illegal arrest and statements obtained had been broken, and the statements were thus the result of free will.[6]
Decisionedit
In the case syllabus, the Court sums up its holding in three parts:
"The Illinois courts erred in adopting a per se rule that Miranda warnings in and of themselves broke the causal chain so that any subsequent statement, even one induced by the continuing effects of unconstitutional custody, was admissible so long as, in the traditional sense, it was voluntary and not coerced in violation of the Fifth and Fourteenth Amendments."[7]
"The question whether a confession is voluntary under Wong Sun must be answered on the facts of each case."[7]
"The State failed to sustain its burden in this case of showing that petitioner's statements were admissible under Wong Sun."[8]
Writing for a unanimous court, Justice Blackmun held that reading a defendant their Miranda Rights does not remove the taint of an illegal arrest.[9] The Court acknowledges that under Wong Sun statements and evidence obtained from an illegal search can be admissible if the connection between the search and the evidence is so attenuated that the taint is dissipated.[10] However, the Supreme Court held that attenuation under Wong Sun requires a showing on the facts of the individual case. Allowing Miranda Rights to automatically attenuate an illegal search would dilute the exclusionary rule.[11]
Under the attenuation doctrine, evidence obtained through government misconduct is admissible if "the connection between the misconduct and the discovery of the evidence is attenuated —weakened— so as to make the evidence untainted by the government's conduct."[12] Because there was no intervening event in the two hours between Mr. Brown's illegal arrest and the first statement that he made, the trial court erred in admitting it. Similarly, as the second statement was a direct result of the first statement, it too is inadmissible.[13]
^Stratton, Brent D., The Attenuation Exception to the Exclusionary Rule: A study in Attenuated Principle and Dissipated Logic, 75 J.Crim.L. & Criminology 139 (1984)
Text of Brown v. Illinois, 422U.S. 590 (1975) is available from:FindlawJustiaLibrary of CongressOyez (oral argument audio)
May 02, 2024
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Brown v Illinois 422 U S 590 1975 was a case in which the Supreme Court of the United States held that the Fourth Amendment s protection against the introduction of evidence obtained in an illegal arrest is not attenuated by reading the defendant their Miranda Rights Brown v IllinoisSupreme Court of the United StatesArgued March 18 1975Decided June 26 1975Full case nameRichard Brown v State of IllinoisCitations422 U S 590 more 95 S Ct 2254 45 L Ed 2d 416Case historyPriorPeople v Brown 56 Ill 2d 312 307 N E 2d 356 1974 cert granted 419 U S 894 1974 HoldingMiranda warnings do not automatically purge the taint of an unlawful arrest A court must examine the time between the arrest of a suspect and the suspect s confession any intervening circumstances and the purpose and the flagrancy of official misconduct when determining if the confession of a properly Mirandized but illegally arrested suspect may be admitted as evidence Court membershipChief Justice Warren E Burger Associate Justices William O Douglas William J Brennan Jr Potter Stewart Byron WhiteThurgood Marshall Harry BlackmunLewis F Powell Jr William RehnquistCase opinionsMajorityBlackmun joined by Burger Douglas Brennan Stewart MarshallConcurrenceWhiteConcurrencePowell joined by Rehnquist Contents 1 History 2 Decision 3 See also 4 References 5 External linksHistory editOn May 13 1968 Richard Brown was arrested outside of his Chicago IL apartment by two members of the Chicago Police 1 The two officers William Nolan and William Lenz entered Mr Brown s apartment without probable cause later testifying that they had entered to question Brown concerning the death of Roger Corpus who had been killed a week prior 1 Following his arrest Mr Brown was taken to a police station for interrogation prior to beginning his interrogation Mr Brown was read his Miranda Rights 2 During interrogation Mr Brown produced a two page written document acknowledging his role in the killing of Roger Corpus 3 Mr Brown would later give another statement to the Assistant State s Attorney assigned to the case again acknowledging his role in Mr Corpus death but also containing a number of factual inaccuracies 4 Both statements would later be introduced at trial ultimately resulting in Mr Brown s conviction for the murder of Roger Corpus 5 On review the Illinois Supreme Court held that by giving Mr Brown Miranda Warnings the causal chain between the illegal arrest and statements obtained had been broken and the statements were thus the result of free will 6 Decision editIn the case syllabus the Court sums up its holding in three parts The Illinois courts erred in adopting a per se rule that Miranda warnings in and of themselves broke the causal chain so that any subsequent statement even one induced by the continuing effects of unconstitutional custody was admissible so long as in the traditional sense it was voluntary and not coerced in violation of the Fifth and Fourteenth Amendments 7 The question whether a confession is voluntary under Wong Sun must be answered on the facts of each case 7 The State failed to sustain its burden in this case of showing that petitioner s statements were admissible under Wong Sun 8 Writing for a unanimous court Justice Blackmun held that reading a defendant their Miranda Rights does not remove the taint of an illegal arrest 9 The Court acknowledges that under Wong Sun statements and evidence obtained from an illegal search can be admissible if the connection between the search and the evidence is so attenuated that the taint is dissipated 10 However the Supreme Court held that attenuation under Wong Sun requires a showing on the facts of the individual case Allowing Miranda Rights to automatically attenuate an illegal search would dilute the exclusionary rule 11 Under the attenuation doctrine evidence obtained through government misconduct is admissible if the connection between the misconduct and the discovery of the evidence is attenuated weakened so as to make the evidence untainted by the government s conduct 12 Because there was no intervening event in the two hours between Mr Brown s illegal arrest and the first statement that he made the trial court erred in admitting it Similarly as the second statement was a direct result of the first statement it too is inadmissible 13 See also editWong Sun v United States 371 U S 471 1963 Utah v Strieff Fruit of the Poisonous TreeReferences edit a b Brown v Illinois 422 U S 590 592 1975 422 U S at 593 94 422 U S 594 95 422 U S at 595 422 U S at 596 56 Ill 2nd at 315 a b 422 U S at 590 422 U S at 591 Brown v Illinois Oyez Retrieved March 7 2023 422 U S at 598 99 422 U S at 602 Stratton Brent D The Attenuation Exception to the Exclusionary Rule A study in Attenuated Principle and Dissipated Logic 75 J Crim L amp Criminology 139 1984 422 U S at 604 05 External links editText of Brown v Illinois 422 U S 590 1975 is available from Findlaw Justia Library of Congress Oyez oral argument audio Retrieved from 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