New York v. Harris

New York v. Harris, 495 U.S. 14 (1990) ^[1], is a U.S. Supreme Court case that addressed whether a confession obtained at a police station is admissible when the arrest was made illegally inside the suspect’s home without a warrant—violating Payton v. New York (1980). Bernard Harris was arrested in his apartment without a warrant though police had probable cause for the murder of Thelma Staton. When the police came to his apartment Harris willingly let them in and after being read his Miranda Rights, Harris answered questions at his house before being taken to the police station for more questioning. Harris gave a written confession at the police station and the confession at the police station was what was used to convict him. The court ruled 5-4 that the confession was admissible because it was made outside of the home after Miranda rights warnings, and was not protected by Payton. The ruling narrowed the exclusionary rule, which prevents use of evidence obtained through unconstitutional means^[2].

In 1984, Thelma Staton was murdered in her apartment. Police had probable cause to believe Bernard Harris was the killer and went to his house without a warrant and arrested Harris which violated Payton. While at the police station Harris was read his Miranda rights and still chose to give a written confession, this confession was used in his trial that helped convict him. There were two other confessions that were suppressed during his trial, even though both of those times he was also read his Miranda rights^[1]. When appealed the New York State of appeals found the confession to be inadmissible as evidence because it was obtained by an illegal arrest. The State appealed^[3].

Payton v New York is a Supreme Court case that determined whether police could enter into a person's home without a warrant. Payton v New York took into account two previous cases one against Theodore Payton and the other was Obie Riddick^[4].

On January 14, 1970, a gas station manager had been killed. A few days later police had secured enough probable cause evidence to believe it was Theodore Payton. Detectives and police went to Payton's house without a warrant and arrested him. Evidence that was found at his house was used in court because of New York Code of Criminal Procedure.

The second case, Obie Riddick was arrested in 1974 for the commission of two armed robberies that had occurred in 1971. The victims in the armed robbery identified Riddick in 1973 and by March 1974 police had found where he lived. Police went to Riddick's house without a warrant and when his son answered the door police saw Riddick laying on his bed and arrested him. Police searched his house immediately following his arrest and found drugs and charged him with possession of narcotics. The trial judge held that the warrantless entry into his home was authorized by the revised New York statute.

Combined both cases helped land a landmark Supreme Court decision that the Fourth Amendment prohibits officers from making a warrantless, nonconsensual entry into a person's home to make a routine felony arrest, even if police officers have probable cause.

The Supreme Court in a 5-4 decision ruled:

• Payton protects statements made at the home but does not protect against statements made somewhere else.
• Harris was read his Miranda rights at the police station and freely gave his written confession to police. This was not done illegally at his home.
• The police had probable cause to arrest Harris and therefore the arrest wasn't unlawful.

Justice Marshall, along with Justices Brennan, Blackmun, and Stevens dissented with the courts decision saying it undermined Payton v New York and created incentives for police to violate a persons Fourth Amendment.

Marshall stated ignoring the precedent allowed for police misconduct to go uncorrected. He accused the majority of creating a more broad rule: if police have probable cause, they may use a statement made outside the home even if it follows an illegal in-home arrest. Only throwing out evidence collected in the home won't stop police from breaking the rules^[2][3]. Harris's written confession was obtained only an hour after being taken to the police station, where police regularly violated Payton v New York to avoid giving the suspect an attorney right away. Judges in the marjority were riding the line to use reasoning to support what the police had done^[3].

New York v Harris narrowed the scope of the exclusionary rule by distinguishing between evidence obtained inside the home during an unlawful entry and statements made later outside the home^[2][3]. Legal commentators have noted that the decision created a potential incentive for police to conduct illegal in-home arrests, knowing that a subsequent confession at the station house might still be admitted at trial so long as Miranda warnings were given. Critics argued that this reasoning weakened the protections established in Payton v New York and blurred the limits of Fourth Amendment safeguards against unlawful searches and seizures.

The case has been cited in later decisions as an example of the Court’s trend during the late 20th century toward limiting the reach of the exclusionary rule.