Dunaway v. New York (1978)
- Docket
- 78-5066
- Decided
- 1978-01-01
Summary
Question: Is bringing a suspect into custody for questioning subject to the same probable cause standards as an arrest? Conclusion: Yes. Justice William J. Brennan, Jr. delivered the opinion of the 6-2 majority. The Supreme Court held that the police violated Dunaway’s Fourth and Fifth Amendment rights by picking him up and taking him to the police station to be questioned without probable cause. Because picking someone up for questioning involves an intrusion on par with that of an arrest, it is held to the standard of “probable cause” rather than the lower standard of “reasonable suspicion.” The Court also held that the confession stemmed directly from the illegal questioning, and without an intervening event, the confession should have been considered tainted evidence and not allowed into evidence at trial. Justice Byron R. White wrote a concurring opinion in which he argued that the key principle of the Fourth Amendment was the balancing of competing interests. He wrote that, while there must be general rules for police conduct, cases should be considered based on their individual facts. In this case, the questioning was too close to an arrest to fit any other criteria. In his concurring opinion, Justice John Paul Stevens wrote that an illegal arrest is only relevant to determining the voluntariness of a confession if it can be shown that the conduct of the illegal arrest was what motivated the confession. Justice William H. Rehnquist wrote a dissent, arguing that not all interactions between citizens and police officers are seizures of persons. Because Dunaway willingly accompanied officers to the police station, his time at the police station could not be deemed a seizure. He also argued that, because the police acted in good faith and gave Dunaway the Miranda warnings, his statements and drawings should be considered voluntary and admissible. Chief Justice Warren E. Burger joined in the dissent. Justice Lewis F. Powell, Jr. did not participate in the discussion or decision of this case.