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RESEARCH
Officers had probable cause the defendant committed a murder. They went to his apartment to arrest him without a warrant. After arriving, the officers knocked on the door, displayed their guns and badges, and entered the defendant’s apartment without consent. Once inside, the officers read the defendant his Miranda rights, which he waived. In response to the officers’ questions, the defendant admitted his guilt in an oral statement and was arrested. The officers took the defendant to the police station, and again informed him of his Miranda rights. For a second time, the defendant admitted his guilt, this time in a signed, written statement. A third statement, this time videotaped, was later obtained from the defendant, even though he indicated that he wanted to end the interrogation. At trial, the defendant’s first and third statements were suppressed, while his second statement was admitted into evidence. The defendant was convicted of second-degree murder.
Whether the defendant’s second statement (the written statement taken at the police station) should have been suppressed because the police violated his Fourth Amendment protections?
No. Where the government has probable cause to arrest a suspect, the exclusionary rule does not bar the government’s use of a statement made by the defendant outside of his home, even though the statement was obtained after an illegal entry into the home.
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.
495 U.S. 14, 110 S. Ct. 1640 (1990)
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