New York v. Harris
495 U.S. 14, 110 S.Ct. 1640, 109 L.Ed.2d 13 (1990)
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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 in violation of the Fourth Amendment's warrant requirement as established in Payton v. New York.
Facts:
- New York City police found Thelma Staton murdered in her apartment on January 11, 1984.
- Police developed probable cause to believe that Bernard Harris had killed Ms. Staton.
- On January 16, five days after the murder, three police officers went to Harris's apartment to arrest him without first obtaining a warrant.
- The officers knocked, displayed their guns and badges, and Harris allowed them to enter.
- Once inside, police read Harris his Miranda rights, and he admitted to the killing.
- Harris was arrested and transported to the police station.
- At the station house, about one hour after the arrest, police again gave Harris his Miranda warnings, and he signed a written inculpatory statement.
Procedural Posture:
- Harris was charged in a New York trial court with second-degree murder.
- The trial court suppressed Harris's first (in-home) and third (videotaped) statements, but ruled the second (written station house) statement was admissible.
- After a bench trial, Harris was convicted.
- Harris appealed to the New York Supreme Court, Appellate Division, which affirmed the conviction.
- Harris appealed to the New York Court of Appeals, the state's highest court, which reversed the conviction, holding that the station house statement was inadmissible fruit of the illegal arrest.
- The State of New York successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the exclusionary rule bar the admission of a statement made by a suspect at the police station, after being given Miranda warnings, when the police had probable cause to arrest the suspect but arrested him in his home without a warrant in violation of Payton v. New York?
Opinions:
Majority - Justice White
No. The exclusionary rule does not bar the State’s use of a statement made by a defendant outside of his home, even if the statement follows an arrest made in the home that violates Payton v. New York, so long as police had probable cause to make the arrest. The purpose of the Payton rule is to protect the physical integrity of the home, not to grant criminal suspects protection for statements made outside their premises. Because the police had probable cause, Harris was not unlawfully in custody when he was removed to the station house. Therefore, his statement at the station was not an inadmissible fruit of the illegal entry because it was not the product of the fact that the arrest was made in the house rather than somewhere else. Suppressing the station house statement would not serve the deterrent purpose of the Payton rule, as police are already deterred from illegal entries because any evidence found inside the home will be suppressed.
Dissenting - Justice Marshall
Yes. The written statement is the direct fruit of a flagrant constitutional violation and must be suppressed to deter police misconduct. The majority creates a new per se rule that improperly ignores the established attenuation analysis from Brown v. Illinois, which considers the time elapsed, intervening circumstances, and the purpose and flagrancy of the violation. Here, only an hour passed, no significant intervening circumstances occurred, and the violation was a knowing and intentional part of a departmental policy to circumvent a suspect's rights. The psychological shock of a forcible, warrantless home arrest does not vanish at the doorstep and is causally connected to the subsequent confession. The majority's rule creates a powerful and dangerous incentive for police to intentionally violate the Fourth Amendment.
Analysis:
This decision significantly limits the scope of the 'fruit of the poisonous tree' doctrine by carving out an exception for statements made following an illegal home arrest. By separating the illegality of the entry from the legality of the custody (when supported by probable cause), the Court narrows the application of the exclusionary rule. The ruling signals that the Court will not apply the rule where it believes the deterrent effect on police misconduct is minimal. This precedent makes it more difficult for defendants to suppress confessions obtained after a Payton violation, as long as the police had probable cause for the arrest itself.
