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 defendant is illegally arrested without a warrant in his home.
After his conviction for murder, the defendant Patrick Cox contended that his warrantless arrest violated the Fourth and Fourteenth Amendments to the United States Constitution because the police unconstitutionally crossed the threshold of his home by opening the screen door, forcibly prevented him from closing the front door, and reached into the house to pull him out. He also contended that his subsequent confession should have been suppressed under the fruit of the poisonous tree doctrine.
Was the arrest in the defendant’s home without a warrant violated the Fourth Amendment of the United States Constitution and therefore incriminating statements he made to police at the police station after the arrest should have been suppressed?
The court held even if the arrest was a violation of the federal constitution, the statement was admissible under the rule that where the police had probable cause to arrest a suspect, the exclusionary rule did not bar the state's use of a statement made by the defendant outside of his home, even though the statement was taken after the arrest made in the home was illegal. Because the defendant made his statement outside of his home following the alleged violation, the exclusionary rule did not bar its admission. The court found that the police had probable cause to arrest the defendant when they went to his house, without a warrant, to question him for the shooting.