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.
Questions
Should inculpatory statements resulting from an illegal arrest but after the reading of Miranda rights be admissible in trial?
Conclusions
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No. Justice Harry A. Blackmun delivered the unanimous opinion. The Court held that Miranda warnings are not sufficient to remove the taint of an illegal arrest from statements made in custody. The Court held that the Fourth and Fifth Amendment were meant to work together, so that even if a statement is found to be voluntary as required by the Fifth Amendment, it could still be the result of an illegal search under the Fourth Amendment and therefore inadmissible. Because Brown’s arrest was illegal and the statements clearly stemmed from that arrest, the Court held that the statements were inadmissible.
Justice Byron R. White concurred in the judgment and wrote that the Miranda warnings do not circumvent the requirements of the Fourth Amendment.
Justice Lewis F. Powell, Jr. wrote an opinion concurring in part. He argued that the admissibility of Brown’s statements should be considered in the context of the Fourth Amendment exclusionary rule. He also argued that the case should be remanded because the trial court made no determination regarding probable cause for the original arrest. Justice William H. Rehnquist joined in the concurrence in part.