New York v. Harris Case Brief

Why is the case important?

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

Facts of the case

“On January 1, 1984, officers of the New York City Police Department found Thelma Staton murdered in her apartment. Various facts of the case linked Bernard Harris to the crime. On January 16, police officers responded to Harris’ house to take him into custody. Although the police had not obtained an arrest warrant, when they knocked on his door, Harris let them enter. The police officers read Harris his Miranda rights, and Harris admitted to committing the murder. The police officers arrested Harris and took him to the police station, where he was read his Miranda rights again and signed an inculpatory statement. The police then videotaped an incriminating interview between Harris and the district attorney, despite Harris’ requests to cease the interrogation.The trial court suppressed Harris’ initial confession and video interview but allowed the signed statement into evidence. After a bench trial, Harris was convicted of second-degree murder. The Appellate Division affirmed the conviction. The Court of Appeals of New York reversed and found the signed statement inadmissible because it was the fruit of an illegal arrest.”

Question

Whether 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?

Answer

“The majority observed, for 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, it 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 ‘the 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 declined 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.

    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.

    • Case Brief: 1990
    • Petitioner: New York
    • Respondent: Bernard Harris
    • Decided by: Rehnquist Court

    Citation: 495 US 14 (1990)
    Argued: Jan 10, 1990
    Decided: Apr 18, 1990
    Granted Apr 17, 1989