finding that detention for custodial interrogation “intrude[d] so severely on interests protected by the Fourth Amendment as necessarily to trigger the traditional safeguards against illegal arrest,” and finding that officers “violated the Fourth and Fourteenth Amendments when, without probable cause, they seized petitioner and transported him to the police station for interrogation”
How later courts described this case
- finding that detention for custodial interrogation “intrude[d] so severely on interests protected by the Fourth Amendment as necessarily to trigger the traditional safeguards against illegal arrest,” and finding that officers “violated the Fourth and Fourteenth Amendments when, without probable cause, they seized petitioner and transported him to the police station for interrogation”
- holding that, while an inculpatory statement given after Miranda warnings may be voluntary under the Fifth Amendment’s privilege against self-incrimination, the statement violates the Fourth Amendment’s protection against unreasonable searches and seizures if the defendant’s arrest was illegal and there was an insufficient attenuation between the unlawful arrest and the statement
- finding Fourth Amendment violation where police lacked probable cause but made functional equivalent of arrest because, instead of "question[ing] [suspect] briefly where he was found," police took him "from a neighbor's home to a police car, transported [him] to a police station, ... placed [him] in an interrogation room[, and] ... never informed [him] that he was `free to go'"
- holding that the petitioner was seized without probable cause based only on a tip from a jail inmate that admittedly did not supply enough information to obtain a warrant, brought to police headquarters and placed in an interrogation room where he was questioned “in the hope that something might turn up,” and confessed without any intervening circumstances
Written by the judges who cited it.
Later courts went against this
Declined to follow by People v. Wise, 82 A.D.2d 869 (1981)
) However, we decline to apply the rule of Dunaway v New York (supra) to cases in which a defendant’s appeal has already been taken-and exhausted.
Distinguished
Distinguished by United States v. Henderson, 303 F. App'x 30 (2008)
Henderson cites Kaupp v. Texas, 538 U.S. 626, 123 S.Ct. 1843, 155 L.Ed.2d 814 (2003), and Dunaway v. New York, 442 U.S. 200, 99 S.Ct. 2248, 60 L.Ed.2d 824 (1979), but those cases are inapposite.
Distinguished by United States of America, State of California, Intervenor v. Raphyal Crawford, AKA Aarmyl Crawford, 372 F.3d 1048 (2004)
With a certain prescience, we distinguished Brown and Dunaway because, “[i]n each of those cases, the defendant was arrested without probable cause,” whereas Manuel was “totally different from Dunaway and Brown because probable cause [to arrest] was amply established before the officers began their interrogation.
Distinguished by United States v. Hopson, 134 F. App'x 781 (2004)
Dunaway v. New York, 442 U.S. 200, 99 S.Ct. 2248, 60 L.Ed.2d 824 (1979), upon which Hopson relies, is inapposite.
Distinguished by State v. Purvey, 129 Md. App. 1 (1999)
442 U.S. 200, 99 S.Ct. 2248, 60 L.Ed.2d 824 (1979), which is inapposite to the facts at hand.
The opinion
Me. Justice White,
concurring.
The opinion of the Court might be read to indicate that Terry v. Ohio, 392 U. S. 1 (1968), is an almost unique exception to a hard-and-fast standard of probable cause. As our prior cases hold, however, the key principle of the Fourth Amendment is reasonableness — the balancing of competing interests. E. g., Delaware v. Prouse, 440 U. S. 648, 653-654 (1979); Michigan v. Tyler, 436 U. S. 499, 506 (1978); Marshall v. Barlow’s, Inc., 436 U. S. 307, 321-322 (1978); United States v. Martinez-Fuerte, 428 U. S. 543, 555 (1976); United States v. Brignoni-Ponce, 422 U. S. 873, 878 (1975); Terry v. Ohio, supra, at 20-21 ; Camara v. Municipal Court, 387 U. S. 523, 536-537 (1967). But if courts and law enforcement officials are to have workable rules, see Rakas v. Illinois, 439 U. S. 128, 168 (1978) (dissenting opinion), this balancing must in large part be done on a categorical basis — not in an ad hoc, case-by- *220 case fashion by individual police officers. Cf. Mincey v. Arizona, 437 U. S. 385, 394-395 (1978). On the other hand, the need for rules of general applicability precludes neither the recognition in particular cases of extraordinary private or public' interests, cf. Zurcher v. Stanford Daily, 436 U. S. 547, 564-565 (1978), nor the generic recognition of certain exceptions to the normal rule of probable cause where more flexibility is essential. Cf., e. g., Terry v. Ohio, supra. It is enough, for me, that the police conduct here is similar enough to an arrest that the normal level of probable cause is necessary before the interests of privacy and personal security must give way.