## Facts

- A Rochester, New York detective received an inmate informant’s lead implicating Irving Jerome Dunaway in a pizza parlor killing during an attempted robbery.
- The detective lacked sufficient information to obtain a warrant or establish probable cause but directed officers to “pick up” Dunaway and “bring him in” for questioning.
- Officers took Dunaway from a neighbor’s home, transported him to the police station, and placed him in an interrogation room.
- Dunaway was not told he was under arrest, but he was not free to leave and would have been physically restrained if he tried.
- Police gave Miranda warnings; Dunaway waived counsel and made incriminating statements and sketches.
- The state courts ultimately admitted the statements and sketches after concluding the police lacked probable cause but treating the detention as permissible on reasonable suspicion and/or finding attenuation.

## Issues

1. Whether the Fourth and Fourteenth Amendments permit police, without probable cause, to seize a suspect and transport him to a station for custodial interrogation under conditions equivalent to arrest.
2. Whether Miranda warnings and Fifth Amendment voluntariness, standing alone, sufficiently attenuate the connection between an illegal seizure and later incriminating statements to permit admission.

## Decision

- The Supreme Court reversed, holding that Dunaway was seized in a manner indistinguishable from a traditional arrest.
- Because the detention was the functional equivalent of arrest, it required probable cause, which police conceded they did not have.
- The Court rejected an intermediate category allowing stationhouse detention for questioning on reasonable suspicion.
- Miranda warnings and a voluntary confession did not, by themselves, purge the taint of the illegal seizure.
- Dunaway’s statements and sketches were fruits of the unlawful detention and should have been suppressed.

## Legal Principles

- Transportation to a police station for custodial interrogation, where the suspect is not free to leave, constitutes an arrest-type seizure requiring probable cause.
- A brief investigatory stop based on reasonable suspicion does not authorize stationhouse custody and interrogation.
- Admission of statements following an illegal arrest requires more than Miranda compliance and Fifth Amendment voluntariness; the prosecution must show attenuation sufficient to dissipate the Fourth Amendment taint.
- Attenuation turns on factors including temporal proximity, intervening circumstances, and the purpose and flagrancy of the misconduct.
- Where questioning occurs during continuous custody initiated by an unlawful seizure, without meaningful intervening events, the causal chain is not broken.

## Conclusion

The Court held that police violated the Fourth and Fourteenth Amendments by seizing and transporting Dunaway for custodial interrogation without probable cause, and that Miranda warnings alone could not cleanse the resulting statements and sketches of the illegality; the evidence was inadmissible as fruit of the unlawful seizure.


Dunaway v. New York, 442 U.S. 200 (1979)