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Law School Case Brief

New York v. Harris - 495 U.S. 14, 110 S. Ct. 1640 (1990)

Rule:

Where 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 the police entered the home without a warrant and without defendant's consent and where exigent circumstances did not exist.

Facts:

Police officers, having probable cause to believe that defendant Bernard Harris committed murder, entered his home without first obtaining a warrant, read him his rights under Miranda v. Arizona, and reportedly secured an admission of guilt. After he was arrested, taken to the police station, and again given his Miranda rights, he signed a written inculpatory statement. On Harris' motion, the New York trial court suppressed the first statement under Payton v. New York, which held that the Fourth Amendment prohibited the police from effecting a warrantless and nonconsensual entry into a suspect's home in order to make a routine felony arrest. However, the court admitted the second statement, and Harris was convicted of second-degree murder. The appellate division affirmed, but the Court of Appeals of New York reversed. Applying the rule of Brown v. Illinois and its progeny that the indirect fruits of an illegal search or arrest should be suppressed when they bear a sufficiently close relationship to the underlying illegality, the court deemed the second statement inadmissible because its connection with the arrest was not sufficiently attenuated. The State filed a petition for a writ of certiorari.

Issue:

Taken into consideration the circumstances of the case, was the written inculpatory statement admissible?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States held that the warrantless arrest in Harris' home did not render the continued custody unlawful, and the statement made at the station was admissible and not barred by the exclusionary rule because probable cause existed. The Court held that the statement was admissible because it was not the fruit of having been arrested in the house rather than someplace else.

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