Taylor v. Alabama

The Court held that a confession obtained through custodial interrogation after an illegal arrest should be excluded unless intervening events break the causal connection between the illegal arrest and the confession. The Court identified several factors that should be considered in determining whether a confession has been purged of the taint of the illegal arrest: time between the arrest and the confession, the presence of intervening circumstances, and, particularly, the purpose and flagrancy of the official misconduct. The government bears the burden of proving that a confession is admissible.

Here, there was no meaningful intervening event. The illegality of the initial arrest was not cured by the facts that six hours elapsed between the arrest and confession, that the confession was “voluntary” for Fifth Amendment purposes because Miranda warnings were given; that the defendant was permitted a short visit with his girlfriend; or that the police did not physically abuse petitioner. Nor was the fact that an arrest warrant, based on a comparison of fingerprints, was filed after the defendant had been arrested.