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Yet, under other circumstances, where a confession that there was whiskey in a suitcase came as the result of an officer's illegally taking the suitcase from a moving train, the Mississippi court held that the Quan rule did not apply and that the admission should not have been allowed in evidence. In the latter case the illegal seizure left the defendant no choice to give or withhold the information; the officer had already seized it. Harris v. State, 209 Miss. 183. The California courts, since adopting the rule of exclusion, have held inadmissible admissions made under the actual compulsion. of an illegal search or arrest. People v. Dixon, 46 Cal. 2d 456 (1956); People v. Macias, 180 Cal. App. 2d 193 (1960). Yet California has held that this rule does not apply to an attempt at bribery made when a person was illegally arrested. People v. Guillory, 178 Cal. App. 2d 854. Thus, even California, which has applied stringent rules in this field, does not hold inadmissible any statement by the defendant which would not have been made but for the unlawful arrest; where the statement is the deliberate and voluntary act of the defendant, California has permitted it to be used.
4. Where a defendant makes statements directly related to things unlawfully seized, the unlawful seizure may well be considered the primary force behind
