State of New York v. Bernard Harris

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



Is the statement of a defendant inadmissible if it is the result of the police entering the defendant's home without a warrant or consent in violation of the Fourth Amendment?

ourt held that the exclusionary rule was designed to protect the physical sanctity of the home, not to grant criminal suspects protection from statements made outside the premises when the police have probable cause for arrest. Since the police had probable cause for an arrest, Harris was not unlawfully in custody when he was read his Miranda rights at the station and made the statement in question.



In his dissent, Justice Thurgood Marshall wrote that Harris’ arrest without a warrant and without exigent circumstances violated the Fourth Amendment, and the signed statement was therefore inadmissible because it was the fruit of an illegal arrest. He argued that the exclusionary rule was meant to prevent police officers from violating the Fourth Amendment in general, and it did not specifically apply to the home. He also argued that there is no evidence that a statement made at the police station is removed from the taint of an illegal arrest. Whether or not Harris was unlawfully in custody at the time his statement was made, he was in custody as a result of an illegal arrest, so the statement was still affected. Justice William J. Brennan, Jr., Justice Harry A. Blackmun, and Justice John Paul Stevens joined in the dissent.