Is Confession of An Unrelated Crime After Arrest by Mistake Admissible ?
In Little v. State, the defendant received Miranda warnings three times before confessing. 758 S.W.2d 551, 566 (Tex. Crim. App. 1988).
It was undisputed that the defendant understood his rights and did not invoke them. Id.
The State estimated that between five and eight hours passed between the arrest and the confession. Id. There was a formal arrest on a valid charge shortly after the illegal arrest and detention, which the court of criminal appeals said transformed the arrest into a legal one. Id.
The arresting officers were not investigating the offense at issue (to which another man had confessed) and initially arrested the defendant, believing him to be someone else. Id.