People v. Allah

Although the hearing court found that the defendant’s arrest was not based on probable cause and was, therefore, illegal, such a conclusion does not automatically result in suppression of any evidence obtained subsequent to the arrest. Suppression does not lie where the means used to obtain the evidence are " 'sufficiently distinguishable to be purged of the primary taint’ ” (Wong Sun v United States, 371 US 471, 488).

In this case, the defendant was identified by the complainant as her assailant from a photo array and a corporeal lineup, both conducted subsequent to his illegal arrest. While…