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imprecations, insults, and admissions were unsolicited, outside police presence, and recorded on the audiotape,” and were admissible although he hadn’t been Mirandized. Frei v. State, 252 Ga.App. 535, 557 S.E.2d 49 (Nov. 20, 2001). “Although the officer testified that he could not specifically remember the day in question, which occurred years ago, he stated that he always read Miranda rights prior to questioning a suspect and that he believed that he had done so in this case. Frei’s signed statement, which reiterated his rights and indicated that the investigating officer had sufficiently apprised him of Miranda, corroborates the officer’s testimony.” Thus, trial court’s determination that Defendant’s confession was admissible is not clearly erroneous as the trial court is “the appropriate arbiter of credibility in this matter.” Harris v. State, 274 Ga. 422, 554 S.E.2d 458 (October 22, 2001). Murder and related convictions affirmed. Defendant, accused of committing malice murder in Georgia, was apprehended in Tennessee. Held, where Tennessee officers advised Defendant of his Miranda rights and obtained a written waiver before Defendant made a statement, Defendant’s subsequent statement to Georgia police officers (made “shortly thereafter”) did not require an additional Miranda waiver to be obtained from Georgia officers because of the continuing nature of the investigation and the short interval between the original waiver and Defendant’s statement to the Georgia investigators. Dickerson v. United States, 530 U.S. 428, 120 S.Ct. 2326, 147 L.Ed.2d 405 (June 26, 2000). Arrested for bank robbery and related offenses, defendant gave a statement to an FBI agent, then moved to suppress it due to lack of Miranda warnings. The District Court granted the motion to suppress, but the Fourth Circuit reversed, based on 18 U.S.C. § 3501. Section 3501 was enacted by Congress two years after Miranda was decided, in an apparent effort to legislatively overrule the warnings requirement and restore the previous “totality of the circumstances” test of voluntariness of a statement. Held, “ Miranda , being a constitutional decision of this Court, may not be in effect overruled by an Act of Congress.” Acknowledges language in other decisions suggesting that Miranda warnings are not constitutionally mandated, and notes that Miranda itself “opined that the Constitution would not preclude legislative solutions that differed from the prescribed Miranda warnings but which were ‘at least as effective in apprising accused persons of their right of silence and in assuring a continuous opportunity to exercise it.’” Scalia, joined by Thomas, dissents, pointing to many prior decisions where the Court has held or implied that “a violation of Miranda is not a violation of the Constitution;” thus, says Scalia, Congress should have the power to legislatively overrule Miranda . State v. Guillory, 236 Ga.App. 230, 511 S.E.2d 591 (February 4, 1999). Trial court properly excluded defendant’s statement as product of illegal arrest. “If there is a causal connection between an illegal arrest and a custodial statement of confession, then the exclusionary rule must be applied to ensure compliance with the Fourth Amendment. Dunaway [ v. New York, 442 U.S. 200, 99 S.Ct. 2248, 60 L.Ed.2d 824 (1979)]; Brown [ v. Illinois, 422 U.S. 590, 95 S.Ct. 2254, 45 L.Ed.2d 416 (1975)]; Wong Sun v. United States, 371 U.S. 471, 83 S.Ct. 407, 9 L.Ed.2d 441 (1963).” State v. Stringer, 258 Ga. 605, 372 S.E.2d 426 (1988). This is so even if a subsequent confession is voluntary. Taylor v. Alabama, 457 U.S. 687, 693, 102 S.Ct. 2664, 73 L.Ed.2d 314 (1982).” “ To determine whether the confession is a product of the illegal arrest, ‘[t]he trial court must determine whether the statements sought to be excluded were obtained by exploitation of the illegality of defendant’s arrest. Thompson v. State, 248 Ga. 343, 344(2), 285 S.E.2d 685 (1981). In addition to whether a detainee has been warned of his rights, the factors which should be considered in determining whether a confession has been purged of the taint of an illegal arrest include the temporal proximity of the arrest and the confession, the presence of intervening circumstances, ... and, particularly, the purpose and flagrancy of the official misconduct. (Cits.) Taylor v. Alabama, 457 U.S. 687, 690(II), 102 S.Ct. 2664, 73 L.Ed.2d 314 (1982).’ (Punctuation omitted.) Paradise v. State, 212 Ga.App. 166, 166-167(1), 441 S.E.2d 497 (1994). Guillory’s confession occurred within one and one-half hours of his arrest and there were no intervening circumstances alleviating the taint of the improper arrest. In fact, according to [Agent] Watson, Guillory’s statements made in his room during the arrest led to further questioning at the Sheriff’s department which resulted in the confession drafted by Watson and signed by Guillory. [Cit.]” 43. VOLUNTARINESS – HOPE OF BENEFIT Finley v. State, 298 Ga. 451, 782 S.E.2d 651 (February 8, 2016). Murder and related convictions affirmed; under pre-2013 Evidence Code, no error in admitting defendant’s custodial statement. The recording doesn’t support defendant’s claim that his statement was induced by detective’s promise that “[y]our quickest way to get [to see your children] ... or your quickest way to take a large load off your shoulders, is just to tell the truth.” “ Even after the detective spoke of the ‘quickest way’ for Finley to see his children—almost an hour into the interview—Finley continued to deny any involvement in the crimes until finally asking to call his mother over two hours into the interview. Moreover,