New York v. Harris

Probable cause does not, by itself, permit officers to intrude into a home to place someone inside under arrest. They must have a warrant, consent, or operate under some exigency (such as hot pursuit). The exclusionary rule may bar evidence discovered inside the home from the government’s use, including, in this case, the defendant’s first statement.

However, when the government has probable cause to arrest, the exclusionary rule will not bar the government’s use of a statement made by the defendant outside of his home, even though the statement was taken after an illegal entry into the home to make an arrest. The rule in Payton was designed to protect the physical integrity of the home, not to grant criminal suspects protection for statements made outside their premises.

There was no valid claim that the defendant was immune from prosecution because his person was the fruit of an illegal arrest. Nor is there any reason that the warrantless arrest required the government to release the defendant. Because the government had probable cause to arrest the defendant for a crime, the defendant was lawfully in custody when he was removed to the police station. The Court noted that any evidence found while illegally in the defendant’s house would have been suppressed as fruits of the illegal entry. However, the defendant’s statement taken at the police station was not the product of being in unlawful custody (as the officers had probable cause to arrest).