New York v. Harris

Brief Fact Summary.

The police arrested an individual in his home without a warrant and he made various incriminating statements.

Synopsis of Rule of Law.

“[W]here the police have probable cause to arrest a suspect, the exclusionary rule does not bar the State’s use of a statement made by the defendant outside of his home, even though the statement is taken after an arrest made in the home in violation of Payton.”

Facts.

The police found the body of a murder victim in an apartment. The officers had probable cause that the Respondent, Bernard Harris (the “Respondent”), killed the victim. Three police officers went to the Respondent’s home to arrest him, but they did not have an arrest warrant. The police knocked on the Respondent’s door and he let them in. They read him his Miranda Rights for a first time. The Respondent agreed to answer questions and admitted to killing the victim. The Respondent was arrested, taken to the police station and read his Miranda rights again. He then signed a written inculpatory statement. The Respondent was then read his Miranda rights a third time and the interviewed on videotape by the district attorney. This took place even though the Respondent said he wanted to end the interrogation.
The trial court suppressed the Respondents’ first and second statements and the state did not challenge those rulings. The New York trial court allowed the other statement to be admitted. The Respondent was then convicted of second-degree murder. The Appellate Division affirmed. The New York Court of Appeals reversed.

Issue.

“[W]hether [the Respondent’s] second statement – the written statement made at the station house – should have been suppressed because the police, by entering Harris’ home without a warrant and without his consent, violated [Payton v. New York], which held that the Fourth Amendment prohibits the police from effecting a warrantless and nonconsensual entry into a suspect’s home in order to make a routine felony arrest[?]”

Held.

The majority observed, “[f]or present purposes, we accept the finding below that [the Respondent] did not consent to the police officers’ entry into his home and the conclusion that the police had probable cause to arrest him.” Further, “[i]t is also evident, in light of Payton, that arresting [the Respondent] in his home without an arrest warrant violated the Fourth Amendment. But, as emphasized in earlier cases, ‘we have declined to adopt a `per se or ‘but for’ rule’ that would make inadmissible any evidence, whether tangible or live-witness testimony, which somehow came to light through a chain of causation that began with an illegal arrest.’ “Instead, “in this context, [the court has] stated that ‘[t]he penalties visited upon the Government, and in turn upon the public, because its officers have violated the law must bear some relation to the purposes which the law is to serve. In light of these principles, [the court] decline[d] to apply the exclusionary rule in this con
text because the rule in Payton was designed to protect the physical integrity of the home; it was not intended to grant criminal suspects, like [the Respondent], protection for statements made outside their premises where the police have probable cause to arrest the suspect for committing a crime.”
“Nothing in the reasoning of that case suggests that an arrest in a home without a warrant but with probable cause somehow renders unlawful continued custody of the suspect once he is removed from the house.”
“[The Respondent’s] statement taken at the police station was not the product of being in unlawful custody. Neither was it the fruit of having been arrested in the home rather than someplace else.” Additionally, “likewise, the police had a justification to question [the Respondent] prior to his arrest; therefore, his subsequent statement was not an exploitation of the illegal entry into [the Respondent’s] home.”
“To put the matter another way, suppressing the statement taken outside the house would not serve the purpose of the rule that made [the Respondent’s] in-house arrest illegal. The warrant requirement for an arrest in the home is imposed to protect the home, and anything incriminating the police gathered from arresting [the Respondent] in his home, rather than elsewhere, has been excluded, as it should have been; the purpose of the rule has thereby been vindicated. We are not required by the Constitution to go further and suppress statements later made by [the Respondent] in order to deter police from violating Payton. As cases considering the use of unlawfully obtained evidence in criminal trials themselves make clear, it does not follow from the emphasis on the exclusionary rule’s deterrent value that ‘anything which deters illegal searches is thereby commanded by the Fourth Amendment.’ ” Even though we decline to suppress statements made outside the home following a Payton violati
on, the principal incentive to obey Payton still obtains: the police know that a warrantless entry will lead to the suppression of any evidence found, or statements taken, inside the home. If we did suppress statements like [the Respondent’s], moreover, the incremental deterrent value would be minimal. Given that the police have probable cause to arrest a suspect in [the Respondent’s] position, they need not violate Payton in order to interrogate the suspect. It is doubtful therefore that the desire to secure a statement from a criminal suspect would motivate the police to violate Payton. As a result, suppressing a station house statement obtained after a Payton violation will have little effect on the officers’ actions, one way or another.”

Discussion.

This case should be read alongside [Payton v. New York] to show how the United States Supreme Court expanded on its Payton holding.