McDonald v. State

We reaffirm the rule established in this jurisdiction that a confession voluntarily given by an accused in custody is not rendered inadmissible by an illegal arrest. 1 See Stewart v. State, 232 Md. 318; Nadolski v. State, 1 Md. App. 304. The “fruit” of an illegal arrest refers to tangible evidence seized; a confession or admission is not a “fruit” of the arrest in this context. Butina v. State, 4 Md. App. 312; Ervin v. State, 4 Md. App. 42. James Arthur McDonald, Jr. (appellant) does not claim that his confession was obtained in violation of the procedural requirements mandated by Miranda v.…