Officers established probable cause the defendant committed a murder. Without obtaining an arrest warrant, the officers went to the defendant’s apartment to arrest him. The officers entered the apartment without the defendant’s consent and read the defendant his Miranda rights. The defendant told the officers he committed the murder and the officers arrested him. At the police station, officers again advised the defendant of his Miranda rights and the defendant provided a written statement in which he admitted to committing the murder.
1. Whether the officers could enter the defendant’s home to arrest him based on probable cause alone?
2. Whether a violation of the rule in Payton v. New York required suppression of the defendant’s statement made to the officers at the police station.
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).
495 U.S. 14, 110 S. Ct. 1640 (1990)