Criminal Procedure keyed to Weinreb
Dunaway v. New York
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The owner of a pizza parlor was killed during an attempted robbery. A few months later, the police received a tip from an informant implicating the Petitioner, Dunaway (the “Petitioner”). A detective questioned the informant and did not learn enough to get an arrest warrant, but nonetheless that Petitioner be brought in. The Petitioner was taken into custody and told he was not under arrest, but he would have been restrained physically if he tried to leave. He was driven to a police station, put in an interrogation room and then mirandized. The Petitioner waived his right to counsel and incriminated himself via statements and drawings. The Petitioner filed motions to suppress the drawings and statements at trial and the motions were denied. The state Appellate Division and Court of Appeals affirmed without opinion. The Supreme Court of the United States vacated the judgment against the Petitioner and remanded in light of the decision in [Brown v. Illinois]. The Petitioner here, like in Brown, “made inculpatory statements after receiving Miranda warnings during custodial interrogation following his seizure – in that case a formal arrest – on less than probable cause.” Also, the petitioner in Brown’s motion to suppress was denied and the statements were used to convict him. The Supreme Court held in Brown that the lower court “erred in adopting a per se rule that Miranda warnings in and of themselves sufficed to cure the Fourth Amendment violation; rather the Court held that in order to use such statements, the prosecution must show not only that the statements meet the Fifth Amendment voluntariness standard, but also that the causal connection between the statements and the illegal arrest is broken sufficiently to purge the primary taint of the illegal arrest in light of the distinct policies and interests of the Fourth Amendment.” The New York Court of Appeals directed that the trial court “to make further factual findings as to whether there was a detention of petitioner, whether the police had probable cause, ‘and, in the event there was a detention and probable cause is not found for such detention, to determine the further question as to whether the making of the confessions was rendered infirm by the illegal arrest.’ ” The trial court found that the motion to suppress should have been granted, but the Appellate Division reversed. The state Court of Appeals dismissed the Petitioner’s application for leave to appeal.
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