James Toy and Wong Sun were arrested for the fraudulent and knowing transportation and concealment of heroine. Both were later convicted based on (1) statements made by Toy in his bedroom at the time of arrest; (2) heroin seized by agents from Johnny Yee; and (3) Toy and Sun’s pretrial unsigned confessions. The court of appeals affirmed the convictions, although it found that the arrests of Toy and Sun were illegal because there was neither probable cause nor reasonable grounds for detention.
The U.S. Supreme Court reversed. The Court, while agreeing that Toy’s arrest was illegal, found that statements made by Toy after his arrest were inadmissible against him including statements that led to the finding of heroin on Johnny Yee. Under the Court’s analysis, the evidence was an ‘‘exploitation’’ of the original unlawful arrest. The Court went on to conclude that the unsigned confessions, although admissible at trial, were not enough to convict Toy because they could not be independently corroborated, and statements implicating Toy in Sun’s confession were also inadmissible since they were not in furtherance of a conspiracy.
The Court found that although Sun’s arrest was also unlawful, his unsigned confession was admissible at trial because while he may never had confessed but for the unlawful arrest any link between the arrest and the confession had been broken due to the fact that it was made voluntarily, after release from arrest and with Sun knowing of his rights to counsel and to remain silent.
References and Further Reading
See also Exclusionary Rule; Fruit of the Poisonous Tree