Brown v. Illinois
Annotate this Case
422 U.S. 590 (1975)
U.S. Supreme Court
Brown v. Illinois, 422 U.S. 590 (1975)
Brown v. Illinois
Argued March 18, 1975
Decided June 26, 1975
422 U.S. 590
Petitioner, who had been arrested without probable cause and without a warrant, and under circumstances indicating that the arrest was investigatory, made two in-custody inculpatory statements after he had been given the warnings prescribed by Miranda v. Arizona, 384 U. S. 436. Thereafter indicted for murder, petitioner filed a pretrial motion to suppress the statements. The motion was overruled and the statements were used in the trial, which resulted in petitioner's conviction. The State Supreme Court, though recognizing the unlawfulness of petitioner's arrest, held that the statements were admissible on the ground that the giving of the Miranda warnings served to break the causal connection between the illegal arrest and the giving of the statements, and petitioner's act in making the statements was "sufficiently an act of free will to purge the primary taint of the unlawful invasion." Wong Sun v. United States, 371 U. S. 471, 486.
1. 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. When the exclusionary rule is used to effectuate the Fourth Amendment, it serves interests and policies that are distinct from those it serves under the Fifth, being directed at all unlawful searches and seizures, and not merely those that happen to produce incriminating material or testimony as fruits. Thus, even if the statements in this case were found to be voluntary under the Fifth Amendment, the Fourth Amendment issue remains. Wong Sun requires not merely that a statement meet the Fifth Amendment voluntariness standard, but that it be "sufficiently an act of free will to purge the primary taint" in light of the distinct policies and interests of the Fourth Amendment. Pp. 422 U. S. 600-603.
2. The question whether a confession is voluntary under Wong Sun must be answered on the facts of each case. Though
Miranda warnings are an important factor in resolving the issue, other factors must be considered; and the burden of showing admissibility of in-custody statements of persons who have been illegally arrested rests on the prosecutor. Pp. 422 U. S. 603-604.
3. The State failed to sustain its burden in this case of showing that petitioner's statements were admissible under Wong Sun. Pp. 422 U. S. 604-605.
56 Ill.2d 312, 307 N.E.2d 356 reversed and remanded.
BLACKMUN, J., delivered the opinion of the Court, in which BURGER, C.J., and DOUGLAS, BRENNAN, STEWART, and MARSHALL, JJ., joined. WHITE, J., filed an opinion concurring in the judgment, post, p. 422 U. S. 606. POWELL, J., filed an opinion concurring in part, in which REHNQUIST, J., joined, post, p. 422 U. S. 606.
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