State v. Ostroski
In State v. Ostroski, 201 Conn. 534, 518 A.2d 915, 922-23 (Conn. 1986), the Supreme Court of Connecticut considered whether Ostroski's confession to his friend, and fellow inmate, was the fruit of an illegal arrest. Id. The court weighed the three attenuation factors and found that there were "significant intervening events which substantially broke the causal connection between the illegal arrest and the defendant's admission," the most important of which was Ostroski's decision to voluntarily confess to his friend. Id. at 922.
The court stated:
The defendant's voluntary conduct in admitting the killing to his friend was not the product of police exploitation of any prior illegality but was a totally unexpected voluntary admission by the defendant. Allen was not an agent of the police, nor is there any claim that he was. Allen had been the defendant's friend for a period of time prior to this episode. Under the circumstances of this case, we cannot say that the admission to Allen was "'come at by exploitation of the illegality.'" Id. at 923 .