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illegal arrest and the confession so that the confession is sufficiently an act of free will to purge the primary taint.’); Boatright v. State, 225 Ga.App. 181, 183, 483 S.E.2d 659 (1997) (concluding that because the defendant's arrest warrant was based on information obtained from an illegal search, the arrest was illegal and no evidence obtained as a result of it could be introduced at trial).” And “compliance with Miranda and avoidance of other conduct that would itself render a suspect's statements involuntary is not sufficient to eliminate the taint from an improper arrest made a mere two hours earlier. See Taylor, 457 U.S. at 691–692 (holding that giving the defendant three Miranda warnings and allowing him a short visit with his girlfriend did not break the connection between his illegal arrest and the statement he gave six hours after he was arrested); Robinson v. State, 166 Ga.App. 741, 742–743, 305 S.E.2d 381 (1983) (holding that the causal connection between the defendant's illegal arrest and his confession was not broken by any intervening events when he was interrogated after being arrested and advised of his Miranda rights).” 2. OCGA § 24-8-824 does not incorporate a “broad exclusionary rule,” mandating exclusion of fruits of involuntary statements; rather, it excludes only the statements themselves. “A review of the origins and development of what is now OCGA § 24–8–824 demonstrates that it is a statute based on a common-law rule of evidence that focuses solely on the reliability—the truth or falsity—of confessions, rather than a statute meant to implement constitutional protections against involuntary confessions, which in the past century have come to reflect concerns about fairness, due process, and self-incrimination as well as reliability.” That common law rule expressly allowed for introduction of fruits of a statement, on the theory that a coerced statement isn’t trustworthy, but evidence obtained as a result of it are. In fact, until 1981, a companion Georgia statute expressly codified this principle of admission of fruits; and the repeal of that statute, without explanation, merely returned the law to its original common law status. Disapproving Pitchford v. State, 294 Ga. 230, 235–236, 751 S.E.2d 785 (2013), and Taylor v. State, 274 Ga. 269, 273, 276, 553 S.E.2d 598 (2001) “to the extent that they can be read as indicating that the fruits of statements obtained in violation of § 24–8–824 must be suppressed.” 3. Remanded to consider whether suppression of the fruits of the statements is constitutionally mandated. “[T]he broad exclusionary rule, including the fruits doctrine, does apply to constitutionally involuntary confessions. See [ United States v. Lall, 607 F.3d 1277, 1291 (11 th Cir., 2010)]. See also Michigan v. Tucker, 417 U.S. 433, 446–447, 94 S.Ct. 2357, 41 L.Ed.2d 182 (1974). As explained above, the statutory and constitutional voluntariness standards differ, and while proof that a confession was induced by a hope of benefit in violation of the statute is significant proof that due process was also infringed, the court must consider that factor among the totality of the circumstances.” Ellington v. State, 292 Ga. 109, 735 S.E.2d 736 (November 19, 2012). Murder convictions affirmed, but death sentence reversed and remanded; trial court properly admitted defendant’s statements to investigators which he initiated at jail, hours after custodial statements which trial court excluded as not voluntary. “‘When a prior statement is actually coerced, the time that passes between confessions, the change in place of interrogations, and the change in identity of the interrogators all bear on whether that coercion has carried over to the second confession.’ Oregon v. Elstad, 470 U.S. 298, 310, 105 S.Ct. 1285, 84 L.Ed.2d 222 (1985). … The trial court found that Ellington's jailhouse statements were ‘[v]oluntary, spontaneous outbursts,’ that they were made in an encounter that he initiated, that they were not made in response to any questioning, that they were made several hours after his interrogation by Sergeant Germano and Detective Bryant ended, that they were made in a different location than that interrogation, and that they were made to different officers outside the presence of Sergeant Germano and Detective Bryant. These findings of fact are fully supported by the record, and we agree with the trial court that they demonstrate a sufficient break from Ellington's earlier, involuntary statements to render his jailhouse statements voluntary and admissible.” Devega v. State, 286 Ga. 448, 689 S.E.2d 293 (February 1, 2010). Trial court properly denied motion to suppress statements of defendant obtained upon warrantless arrest of defendant for drug charges by city police officer outside city limits, where arrest was supported by probable cause. “‘Where probable cause exists, even an illegal, warrantless arrest in a suspect's home does not render inadmissible subsequent statements made outside the premises. [Cits.]’ Pittman v. State, 277 Ga. 475, 479(4) (592 S.E.2d 72) (2004). Thus, even if we assume that the warrantless arrest in this case was illegal because the officers were outside their jurisdiction, suppression of the fruits of that arrest is not required because the arrest was made with sufficient probable cause and in an office, rather than in the sanctity of the home. See State v. Giangregorio, 181 Ga.App. 324, 325 (352 S.E.2d 193) (1986) (upholding arrest and subsequent search of defendant at airport in Clayton County by DeKalb County officer who was working on multi-agency drug task force, but had not been sworn as a Clayton County deputy).” Vergara v. State, 283 Ga. 175, 657 S.E.2d 863 (February 25, 2008). Defendant’s Sixth Amendment rights were violated when he was interviewed by detective after requesting counsel at first appearance in Magistrate Court. Defendant had been arrested for murder; interview related to search for drugs. Both statement and drugs discovered as a result should have been suppressed. “Where physical evidence discovered as a consequence of a defendant’s inadmissible