Facts
Corpus was murdered and Brown’s name was one provided. Officers went to Brown’s apartment, waited for him to arrive, and arrested him. The police did not have probable cause or a warrant for the arrest. While in custody, Brown was informed of his rights under Miranda. Questioning of Brown came to two admissions that he and Claggett were involved in the murder of Corpus.
Procedural History
Brown moved to suppress the two statements he had made, claiming that the arrest was illegal and thus the statements were in violation of his constitutional rights. The motion was denied and Brown was convicted. The Illinois Supreme Court affirmed, finding that although the arrest was illegal, the statements were an act of free will.
Issue(s)
Did the Illinois Supreme Court err in finding that the statements made by Brown, although after an illegal arrest, were properly admitted by the trial court.
Holding(s)
Yes.
Reasoning/Analysis
The Court found that Miranda warnings, alone and per se, cannot always make the act sufficiently a product of free will; they cannot assure in every case that the Fourth Amendment violation has not been unduly exploited. We therefore reject the per se rule articulated by the Illinois Supreme Court and also decline to adopt any alternative per se rule.
Judgment/Outcome
The Court reversed and remanded the judgment of the Illinois Supreme Court.
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