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New York v. Harris | 495 U.S. 14 (1990)

In Payton versus New York, the United States Supreme Court held that if police officers entered a defendant’s home in violation of the Fourth Amendment and obtained evidence inside the home, that evidence generally must be suppressed under the Fourth Amendment’s exclusionary rule. But what if officers unconstitutionally entered a defendant’s home, removed him from the home after arresting him based on probable cause, and then obtained his confession outside the home? Does the exclusionary rule require suppression of that confession? The Court addressed that issue in New York versus Harris.

Officers had probable cause that Bernard Harris committed a murder, but they didn’t obtain a search or arrest warrant. Instead, the officers unconstitutionally entered Harris’s home and arrested him. While still inside his home, they obtained Harris’s confession after reading him Miranda warnings. The officers then took Harris to the police station, read him Miranda warnings again, and obtained Harris’s second confession to the murder.

The state charged Harris with murder. Harris moved to suppress both confessions under the Fourth Amendment, contending that both were tainted fruit of the officers’ unconstitutional entry into his home. The state trial court suppressed Harris’s in-home confession but refused to suppress Harris’s confession at the police station. Harris was convicted of murder after a bench trial at which the prosecution offered evidence of Harris’s confession at the police station. The state intermediate appellate court affirmed the trial court’s judgment, but the New York Court of Appeals reversed Harris’s conviction, concluding that Harris’s second confession should’ve been suppressed under the Fourth Amendment. The state high court specifically applied a taint-attenuation analysis under Brown versus Illinois and concluded that Harris’s confession at the police station was tainted by the officers’ unconstitutional entry into Harris’s home.

The state successfully petitioned the United States Supreme Court to review Harris’s case.

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