Brown v. Illinois, 422 U.S. 590 (1975), was a case in which the Supreme Court of the United States held that the Fourth Amendment's protection against the introduction of evidence obtained in an illegal arrest is not attenuated by reading the defendant their Miranda Rights.

[2] During interrogation Mr. Brown produced a two-page written document acknowledging his role in the killing of Roger Corpus.

[3] Mr. Brown would later give another statement to the Assistant State's Attorney assigned to the case again acknowledging his role in Mr. Corpus' death but also containing a number of factual inaccuracies.

[10] However, the Supreme Court held that attenuation under Wong Sun requires a showing on the facts of the individual case.

"[12] Because there was no intervening event in the two hours between Mr. Brown's illegal arrest and the first statement that he made, the trial court erred in admitting it.