The following excerpt is from United States v. Ramirez, 976 F.3d 946 (9th Cir. 2020):
violations ..., the government must go beyond showing that the confession was voluntaryit must also show a sufficient break in events to undermine the inference that the confession was caused by the Fourth Amendment violation. " (quoting Oregon v. Elstad , 470 U.S. 298, 306, 105 S.Ct. 1285, 84 L.Ed.2d 222 (1985) )).
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