When police officers detain a person, against his will, in a significant way so that he does not have the freedom to leave or move about they have essentially arrested the person. In order for that arrest to be legal the officers must have had enough evidence to equal probable cause. Normally, any evidence obtained after an illegal arrest, and pursuant to that same arrest, is inadmissible in a court of law. These are issues that the U. S. Supreme Court has examined for decades under the protections of the 4th Amendment to the Constitution. The 4th Amendment protects our interests in our "persons, houses, papers, and effects, from unreasonable searches and seizures...." An arrest is a seizure; therefore, the 4th Amendment applies. If an out-of-court identification is related to the illegal arrest, then, it would stand to reason that the later in-court identification is the fruit of that illegal action. If the causal link is present, and no exception applies, the in-court identication is analyzable under the fruit of the poisonous tree doctrine.