The government arrested the defendant without probable cause and without a warrant, and under circumstances indicating that the arrest was part of an investigation. The defendant made two in-custody incriminating statements after he had been given Miranda warnings.
Whether being advised of his Miranda protections adequately removed the taint of the illegal arrest so as to allow the government the right to use the statements against the defendant at his trial?
It depends. Providing Miranda warnings to a suspect that was illegally arrested is only one factor in determining whether the “taint” of the illegal seizure has evaporated.
The Court held that the exclusionary rule serves different interests and policies under the Fourth and Fifth Amendment. The state court erred in adopting a per se rule that Miranda warnings in and of themselves break the causal chain between an illegal seizure (Fourth Amendment) and any subsequent statement (Fifth Amendment). Miranda warnings do not automatically amend Fourth Amendment transgressions. Thus, even if the statements in this case were found to be voluntary under the Fifth Amendment, the Fourth Amendment issue remained.
The question about whether a confession is voluntarily given must be answered on the facts of each case. Though the Miranda warnings are an important factor in resolving the issue, other factors must be considered. Trial courts should consider: the temporal proximity of the arrest to the confession, the intervening circumstances, and, particularly, the purpose and flagrancy of the official misconduct. The burden of showing admissibility of in-custody statements of persons who have been illegally arrested rests with the government.
422 U.S. 590, 95 S. Ct. 2254 (1975)