Brown v. Illinois Case Brief

Why is the case important?

Suspect was arrested without probable cause, given Miranda twice, and confessed to murder twice.

Facts of the case

“On May 6, 1968, Roger Corpus was shot and killed in his apartment. The police obtained the name of Richard Brown, who was identified as an acquaintance of the victim, though not a suspect. On May 13, 1968, detectives arrested Brown and searched his apartment without probable cause and without a warrant. The detectives read Brown his Miranda rights and proceeded to question him. During the questioning, Brown confessed to assisting in Corpus’ murder. Later, Brown was questioned again after being read his Miranda rights a second time. He substantially repeated his account of the murder.Prior to his trial, Brown moved to suppress the two statements based on the fact that his arrest was illegal and the statements were taken in violation of his Fourth and Fifth Amendment rights. The motion was denied and the case proceeded to trial. The jury found Brown guilty. The Supreme Court of Illinois affirmed the judgment but did not accept the State’s argument that the arrest was legal.”

Question

Whether a Miranda warning sufficiently breaks the causal chain between an illegal arrest and a confession.

Answer

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 appeared 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.

Conclusion

The Supreme Court of the United States reversed the judgment because the state supreme court was in error to conclude that Miranda warnings could always purge the taint of an illegal arrest. The Court held that the Miranda warnings could neither automatically nor by themselves protect an accused’s Fourth Amendment rights. Whether a confession was freely given or improperly coerced had to be determined on a case by case basis. The Court held the trial court had to examine factors such as the temporal proximity of the arrest to the confession, the intervening circumstances, and, particularly, the purpose and flagrancy of the official misconduct. The Court also held that the exclusionary rule did not automatically proscribe the use of illegally seized evidence in all proceedings or against all persons, and that Miranda warnings, along with other factors, might permit the admission of such evidence. However, the Court examined the record in light of those factors and concluded that petitioner’s statements were inadmissible.

  • Case Brief: 1975
  • Petitioner: Richard Brown
  • Respondent: Illinois
  • Decided by: Burger Court

Citation: 422 US 590 (1975)
Argued: Mar 18, 1975
Decided: Jun 26, 1975
Granted Oct 21, 1974