## Facts

- New York City police found Thelma Staton murdered in her apartment and developed probable cause to believe Bernard Harris committed the crime.
- Officers went to Harris’s home to arrest him without an arrest warrant and entered the home.
- Inside the home, police gave Miranda warnings, questioned Harris, and obtained an admission that he killed Staton.
- Police then arrested Harris, took him to the station house, gave Miranda warnings again, and obtained a written inculpatory statement.
- A later videotaped station-house interrogation produced additional incriminating statements after Harris said he wished to stop.

## Issues

1. Whether the exclusionary rule bars the State from using a defendant’s station-house statement made after Miranda warnings when the defendant was arrested in his home in violation of Payton, but police had probable cause to arrest.

## Decision

- The Supreme Court reversed the New York Court of Appeals.
- The Court held that when police have probable cause to arrest, a statement taken from the defendant outside the home is not excluded solely because the arrest followed a Payton-violative home entry.
- Harris’s written station-house confession was admissible (though the in-home statement and other challenged evidence remained suppressed under the lower courts’ rulings).

## Legal Principles

- Payton’s warrant requirement for routine felony arrests in the home primarily protects the home against warrantless entry; suppression should be tied to that protective purpose.
- When police have independent probable cause to arrest, a post-arrest station-house statement obtained outside the home is not treated as the product of the unlawful home entry for exclusionary-rule purposes.
- Extending suppression beyond in-home evidence and statements may be rejected where the additional deterrent benefit is minimal in light of Payton’s targeted protection of the home.

## Conclusion

The Court held that a warrantless, nonconsensual home entry violating Payton does not require suppression of a later Miranda-warned station-house confession when police had probable cause to arrest, because excluding the outside-the-home statement would not meaningfully advance Payton’s home-protection rationale.


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