New York v. Harris

Background

Police suspected Bernard Harris of murdering a woman. Three officers went to his apartment without an arrest warrant. They knocked, showed guns and badges, and Harris let them in. Inside, officers read Miranda warnings, and Harris spoke; he was arrested, taken to the station, and later signed a written statement at the station house.

Reasoning

The main question was whether that written station-house statement had to be excluded because the officers had entered Harris’ home without a warrant. The Court said no. The majority explained that the home-protection rule aims to stop physical invasions of the house. Because the police had probable cause, the Court found Harris was lawfully in custody once removed from the home and that his station-house statement was not the product of the illegal entry. The majority relied on earlier decisions saying evidence is excluded only when it is the direct product of the illegality.

Real world impact

The decision lets prosecutors use statements taken outside the home even when the arrest inside the home lacked a warrant, so long as police had probable cause. That means confessions taken at a station after a warrantless home entry are more likely to be admitted at trial. The ruling focuses suppression on evidence gathered inside the home and does not require excluding all later out-of-home statements.

Dissents or concurrances

Justice Marshall’s dissent warned that this rule weakens deterrence against illegal home entries. He emphasized factors like short time to confession, a possible departmental policy, and intentional violations that, he argued, should lead courts to suppress such statements.