Cox v. State
696 N.E.2d 853 (1998)
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Rule of Law:
Where police have probable cause to arrest a suspect, the exclusionary rule does not bar the use of a statement made by the defendant outside of his home, even if the statement is taken after an arrest made in the home that violates the Fourth Amendment principles established in Payton v. New York.
Facts:
- In the early morning, James Leonard was shot and killed while asleep in his ground-floor bedroom.
- A firearms expert determined the shot was fired from within six inches of the bedroom window screen.
- A friend of Patrick E. Cox informed police that Cox had admitted to looking into the Leonards' window, firing a shot, and fleeing.
- The State's theory was that Cox's motive was retaliation for molestation charges the Leonards had filed against Cox's close friend, Jamie Hammer.
- Two police officers, believing they had probable cause but lacking an arrest warrant, went to Cox's home.
- Cox answered the officers' knock by opening the main front door but leaving a screen door closed.
- When Cox attempted to shut the main door, an officer opened the screen door, blocked the main door, reached inside the house, and pulled Cox out by the arm.
Procedural Posture:
- Patrick E. Cox was charged with murder in an Indiana state trial court.
- Before trial, Cox filed a motion to suppress his incriminating statements made to police, arguing they were the result of an unconstitutional arrest.
- The trial court denied the motion to suppress.
- Following a trial, a jury convicted Cox of murder.
- The jury could not agree on a sentence of life without parole, and the trial court subsequently imposed a sentence of life imprisonment.
- Cox filed a direct appeal of his conviction and sentence to the Supreme Court of Indiana, the state's highest court.
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Issue:
Does the Fourth Amendment's exclusionary rule bar the admission of a defendant's incriminating statement, made at a police station, which followed a warrantless and nonconsensual arrest in his home for which police had probable cause?
Opinions:
Majority - Boehm, Justice
No, the exclusionary rule does not bar the admission of the statement. Although a warrantless and nonconsensual entry into a suspect's home to make a routine felony arrest violates the Fourth Amendment under Payton v. New York, a subsequent statement made by the defendant outside the home is not considered a fruit of that illegal entry if police had probable cause for the arrest. The court relied on New York v. Harris, which held that the purpose of the Payton rule is to protect the physical integrity of the home, not to grant a suspect immunity from prosecution for a statement made at a police station after being lawfully taken into custody. Because the police had probable cause to arrest Cox, his subsequent statement at the station was not a product of the illegal entry but of his lawful detention, and was therefore admissible.
Analysis:
This case affirms and applies the Supreme Court's holding in New York v. Harris, establishing a significant limitation on the 'fruit of the poisonous tree' doctrine. It clarifies that a violation of the Payton rule, which protects the sanctity of the home from warrantless entry, does not automatically taint all subsequent evidence. By separating the illegality of the entry from the legality of the custody (based on probable cause), the decision allows statements made outside the home to be admitted, thereby preventing the exclusionary rule from becoming a get-out-of-jail-free card for defendants who confess after a procedurally flawed but substantively justified arrest. This reinforces the principle that the exclusionary rule's application is tailored to the specific right violated—in this case, the privacy of the home, not the right to be free from arrest based on probable cause.
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