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PEOPLE v. BROWN
Appellate Division of the Supreme Court of New York, First Department.
Nov 21, 1996
This Court has previously determined that additional information received by the police minutes following defendant's unlawful arrest provided an independent basis for probable cause, thereby severing any causal relationship between the unlawful arrest and the subsequent lineup identification ( People v Brown, 215 AD2d 333, lv withdrawn 86 NY2d 791). We find no basis to depart from that determination on this appeal.
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