Brown v. Illinois case brief

Brown v. Illinois case brief summary
422 U.S. 590 (1975)

CASE SYNOPSIS

Petitioner appealed the judgment of the Supreme Court of Illinois, which sustained his conviction for murder and held that petitioner's inculpatory statements made after an undeniably illegal arrest were admissible because the Miranda warnings given by the police after the arrest and prior to the statements sufficiently attenuated the taint of the arrest. The case came before the Court pursuant to a writ of certiorari.

CASE FACTS
Following an illegal arrest, petitioner gave inculpatory statements after he was read his constitutional rights. The statements were admitted at trial on the basis that the Miranda warnings, by themselves, were sufficient to purge the taint of the illegal arrest, making admissible that which would normally be excluded.

DISCUSSION

• On certiorari, 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, the Court held, 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.

CONCLUSION

The Court reversed the judgment of the state supreme court and remanded for further proceedings. The Court held that the state supreme court was in error to conclude that Miranda warnings could always purge the taint of an illegal arrest. The Court examined the record and the facts, because the trial court had not done so, and concluded that petitioner's inculpatory statements were inadmissible under the facts of this particular case.

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