United States v. Hernandez, 670 F.3d 616

Anonymous tip claimed 10–15 illegal aliens were being held in Hernandez's trailer and ICE investigated around midnight.
Officers banged on doors, broke a glass pane, and Hernandez admitted at least one illegal alien was present.
Hernandez, her boyfriend Ayala, and two illegal aliens were detained and taken to ICE for questioning; Hernandez and Ayala waived Miranda rights and confessed; Andrade-Quesada disclosed a payment arrangement for staying with Hernandez.
District court denied suppression; Fifth Circuit previously held the search violated the Fourth Amendment and remanded to assess admissibility of post-Miranda statements.
On remand, Government argued Harris excused taint; court held Hernandez’s doorstep admission lacked probable cause, taint from the Fourth Amendment violation nullified the post‑arrest confession, and Ayala and Andrade‑Quesada were not sufficiently attenuated; conviction and statements were suppressed and remanded.
The court ultimately reversed the denial of suppression, vacated Hernandez’s conviction and sentence, and remanded for proceedings consistent with its opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Hernandez’s post-arrest statement	Hernandez’s admission was admissible under Harris	Admission tainted by Fourth Amendment violation	Post-arrest confession suppressed
Admissibility of Ayala’s and Andrade-Quesada’s statements	Statements would be inevitably discovered	Not sufficiently attenuated or inevitable discovery proven	Statements excluded
Attenuation/inevitable discovery standards applied	Attenuation or inevitable discovery would permit admission	Neither attenuated nor inevitably discovered	Neither exception applied; taint not purged

New York v. Harris, 495 U.S. 14 (1990) (probable cause before illegal entry controlling admissibility of post-arrest statement)
Dunaway v. New York, 442 U.S. 200 (1979) (exclusion of confession following illegal seizure without probable cause)
Brown v. Illinois, 422 U.S. 590 (1975) (consideration of intervening events in determining taint of statements)
Michigan v. Chesternut, 486 U.S. 567 (1988) (seizure analysis; whether suspect was seized and free to leave)
Mendenhall, 446 U.S. 544 (1980) (factors indicating seizure other than consent)
Payton v. New York, 445 U.S. 573 (1980) (home entry without consent or warrant for arrest)
Ceccolini, 435 U.S. 268 (1978) (attenuation and excepting testimony when taint is slight)
Brown v. Williams, 467 U.S. 431 (1984) (attenuation/taint considerations and deterrence)
Wong Sun v. United States, 371 U.S. 471 (1963) (fruit of the poisonous tree doctrine and purging taint)
Miranda v. Arizona, 384 U.S. 436 (1966) (mandatory warnings; voluntariness of statements)
Singh, 261 F.3d 530 (2001) (exclusionary rule beyond mere but-for causation)
Nix v. Williams, 467 U.S. 431 (1984) (inevitable discovery standard)