Brown v. Illinois

422 U.S. 590 (1975)

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Nature of the Case

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Facts

Brown (D) was greeted by two police officers with drawn guns as he was climbing the last of the stairs leading to the rear entrance of his Chicago apartment. D was told not to move and was placed under arrest. The officers said that they made the arrest for the purpose of questioning D as part of their investigation of the murder of a man named Roger Corpus. Detectives had obtained D's name, among others, from Corpus' brother. D and the others were identified as acquaintances of the victim, not as suspects. Before D had arrived and was arrested, the officers had broken into D's apartment and searched it. They then took positions to wait for D. As officers held D at gunpoint, the three entered the apartment. D was ordered to stand against the wall and was searched. No weapon was found. When he denied being Richard Brown, they informed him that he was under arrest for the murder of Roger Corpus, handcuffed him, and escorted him to the squad car. During the drive to the station detectives asked D questions which D evaded or answered falsely. D was placed in the second-floor central interrogation room. The room was bare, except for a table and four chairs. He was left alone, without handcuffs, for some minutes while the officers obtained the file on the Corpus homicide. They returned with the file, sat down at the table, one across from D and the other to his left, and spread the file on the table in front of him. The officers gave him Miranda. warnings. Eventually, D confessed. The statement was signed by D. The detectives then went looking for D's accomplice. The arrested him just after midnight and returned to the station. D was again placed in the interrogation room. He was given coffee and was left alone, for the most part, until 2 a.m. The Assistant State's Attorney informed D of his Miranda rights. After a half hour's conversation, a court reporter appeared. Miranda warnings were given, and D was told he would be charged with murder.' D gave a second statement, providing a factual account of the murder substantially in accord with his first statement, but containing factual inaccuracies with respect to his personal background. D refused to sign it. An hour later he made a phone call to his mother. At 9:30 that morning, about 14 hours after his arrest, he was taken before a magistrate. D moved to suppress the two statements; his arrest and detention had been illegal and that the statements were taken from him in violation of his constitutional rights. The motion was denied. D was found guilty of murder. The Supreme Court of Illinois affirmed the judgment of conviction. It held that the arrest was unlawful but that the Miranda warnings served to break the causal connection between the illegal arrest and the giving of the statements, and that defendant's act in making the statements was `sufficiently an act of free will to purge the primary taint of the unlawful invasion.' The Supreme Court granted certiorari.