Law School Case Brief
Dunaway v. New York - 442 U.S. 200, 99 S. Ct. 2248 (1979)
Detention for custodial interrogation—regardless of its label—intrudes so severely on interests protected by the Fourth Amendment as necessarily to trigger the traditional safeguards against illegal arrest.
Without possessing sufficient information to obtain a warrant, police took defendant Irving Jerome Dunaway into custody in connection with an attempted robbery and homicide, and brought him to police headquarters where he was questioned after being given Miranda warnings. Dunaway was not told when taken into custody that he was under arrest, but would have been physically restrained if he had attempted to leave. At the police station Dunaway waived counsel and eventually made statements and drew sketches incriminating himself in the crime. After trial in New York state court, Dunaway was convicted after his motions to suppress the statements and sketches were denied. State appellate courts affirmed the conviction, but the Supreme Court of United States, in view of a supervening decision possibly affecting the admissibility of the evidence, vacated the judgment and remanded. Ultimately, the state trial court granted Dunaway's motion to suppress. However, the Appellate Division of the New York Supreme Court reversed, holding that although the police lacked probable cause to arrest Dunaway, law enforcement officials could detain him lawfully upon reasonable suspicion for questioning for a reasonable and brief period of time under certain conditions, and that even if Dunaway was illegally detained, the taint of his detention was sufficiently attenuated to permit admission of the incriminating evidence. After the Court of Appeals of New York dismissed Dunaway's application for leave to appeal, Dunaway was granted a petition of certiorari.
Did the state appellate court err by not suppressing Dunaway's incrimination statements and sketches?
The Supreme Court of the United States reversed the appellate division's decision. The Court held that police violated the Fourth and Fourteenth Amendments to the Federal Constitution when, without probable cause to arrest, they took Dunaway into custody, transported him to the police station, and detained him there for interrogation. This detention for custodial interrogation intruded so severely on interests protected by the Fourth Amendment as to trigger the traditional safeguards against illegal arrest. Moreover, the incriminating evidence given to the police during the illegal detention was not admissible at trial, since under appropriate Fourth Amendment analysis, no intervening event broke the connection between Dunaway's illegal detention and the incriminating statements. The giving of Miranda warnings did not render such connection sufficiently attenuated to permit use of the incriminating evidence at trial.
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