Sam, a New Police Officer, Was Criticized by His Supervisor

Sam, a new police officer, was criticized by his supervisor for failing to make a sufficient number of arrests. Sam went into a section of town known for criminal activity, picked up several suspicious looking individuals, read them the Miranda rights, and arrested them hoping that they would confess to something. Alice, one of the detainees, was scared; and, hoping to cut a deal, immediately confessed to burglarizing a local pawn shop. Which of the following is Alice's best defense at trial?

A) That the officer failed to have probable cause to make the arrest.
B) That the officer violated her First Amendment rights.
C) That the officer failed to obtain a form signed by Alice verifying that she understood the Miranda rights as read.
D) That the officer failed to satisfy the burden of proof.
E) That a confession prior to an initial appearance is invalid.