Dunaway v. New York
442 U.S. 200 (1979)
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Rule of Law:
Seizing a suspect for custodial interrogation at a police station without probable cause constitutes a violation of the Fourth and Fourteenth Amendments. A confession obtained following such an illegal seizure must be suppressed, even if Miranda warnings were given, unless the causal chain between the illegal seizure and the confession is broken by significant intervening circumstances.
Facts:
- On March 26, 1971, the proprietor of a pizza parlor in Rochester, New York, was killed during an attempted robbery.
- On August 10, 1971, Detective Fantigrossi received a lead from an informant implicating petitioner Dunaway in the crime.
- After investigating the lead, Fantigrossi concluded there was not enough information to secure an arrest warrant.
- Despite lacking probable cause, Fantigrossi ordered other detectives to "pick up" Dunaway and "bring him in" for questioning.
- On August 11, 1971, three detectives located Dunaway at a neighbor's house and took him into custody.
- Dunaway was not told he was under arrest, but he was not free to leave and would have been physically restrained if he had attempted to do so.
- He was transported to police headquarters in a police car and placed in an interrogation room.
- After being given Miranda warnings, Dunaway waived his right to counsel and made incriminating statements and sketches related to the crime.
Procedural Posture:
- At Dunaway's jury trial in Monroe County Court, his motions to suppress his statements and sketches were denied, and he was convicted.
- Dunaway, as appellant, appealed to the Appellate Division of the Fourth Department, an intermediate appellate court, which affirmed the conviction.
- Dunaway then appealed to the New York Court of Appeals, the state's highest court, which also affirmed.
- The U.S. Supreme Court granted certiorari, vacated the judgment, and remanded the case to the New York courts for reconsideration in light of the supervening decision in Brown v. Illinois.
- On remand, the Monroe County Court held a new hearing and granted Dunaway's motion to suppress.
- The State, as appellant, appealed to the Appellate Division, which reversed the County Court's suppression order.
- The New York Court of Appeals dismissed Dunaway's application for leave to appeal.
- The U.S. Supreme Court granted certiorari to review the Appellate Division's decision.
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Issue:
Does taking a suspect into custody for interrogation at a police station, without probable cause for arrest, violate the Fourth and Fourteenth Amendments, thereby requiring the suppression of a subsequent confession?
Opinions:
Majority - Mr. Justice Brennan
Yes. Taking a suspect into custody for interrogation at a police station is a seizure that requires probable cause under the Fourth Amendment. The narrow exception for brief, on-the-spot detentions based on reasonable suspicion, established in Terry v. Ohio, does not apply to custodial interrogations which are functionally indistinguishable from a traditional arrest. Because the police seized Dunaway without probable cause, his detention was illegal. Following the precedent set in Brown v. Illinois, the subsequent confession must be suppressed as a fruit of the illegal seizure. The administration of Miranda warnings, by itself, is insufficient to break the causal connection between the unconstitutional conduct and the confession, especially where there are no intervening events and the police misconduct was purposeful.
Concurring - Mr. Justice White
Yes. While the key principle of the Fourth Amendment is reasonableness achieved through balancing competing interests, this balancing should be done on a categorical basis to create workable rules for law enforcement. The police conduct in this case was so similar to a formal arrest that the normal requirement of probable cause is necessary. The interests of privacy and personal security must not give way to police intrusion of this magnitude without the traditional safeguard of probable cause.
Concurring - Mr. Justice Stevens
Yes. The admissibility of a confession obtained after an illegal arrest should turn on the causal relationship between the violation and the confession. The flagrancy of police misconduct is relevant only to the extent it motivates the defendant to confess. The primary purpose of the exclusionary rule is not to punish individual officers for their subjective state of mind but to motivate the entire law enforcement profession to adopt and enforce procedures that respect constitutional rights, which requires objective criteria for exclusion.
Dissenting - Mr. Justice Rehnquist
No. The record does not demonstrate that Dunaway was 'seized' within the meaning of the Fourth Amendment; rather, he voluntarily accompanied the police to the station. A seizure occurs only when an officer restrains liberty by physical force or a show of authority, which was absent here. Additionally, even if a seizure did occur, the confession should not be suppressed. Under the Brown v. Illinois factors, the police acted in good faith reliance on existing state law, their conduct was not flagrant, and Dunaway received proper Miranda warnings before voluntarily confessing. The connection between any alleged detention and the confession was sufficiently attenuated to permit its use at trial.
Analysis:
This decision significantly clarifies the Fourth Amendment's limits on police authority, firmly distinguishing between a limited Terry stop and a de facto arrest. It establishes that any seizure of a person that involves transport to a police station for interrogation is a major intrusion requiring probable cause, not merely reasonable suspicion. The case reinforces the principle from Brown v. Illinois that Miranda warnings alone do not cure a Fourth Amendment violation, thereby preventing police from conducting 'fishing expeditions' where they illegally detain suspects hoping to elicit a confession after issuing the warnings. This creates a strong deterrent against seizures based on less than probable cause for investigative purposes.
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