New York v. Harris

In Payton v. New York, the Court held, “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.” Here, while the police had probable cause to arrest the defendant, they entered his home without an arrest warrant and without his consent. Their entry into the defendant’s home violated the Fourth Amendment. Any evidence obtained during this illegal entry is excluded as the fruit of an unreasonable search. However, “the rule in Payton was designed to protect the physical integrity of the home; it was not intended to grant criminal suspects, like the defendant, protection for statements made outside their premises where the police have probable cause to make an arrest.” In this case, the police had probable cause to arrest the defendant prior to entering his home. Because of this, the defendant “was not unlawfully in custody when he was removed to the station house, given Miranda warnings, and allowed to talk.” While the entry into the defendant’s home was illegal, his continued custody outside of the home was lawful. Accordingly, the statement taken at the station house “was not an exploitation of the illegal entry into the defendant’s home” and the exclusionary rule should not apply.