The US Supreme Court Case Dunaway versus New York - Research Paper Example

The United s Supreme Court case Dunaway v. New York (442 U.S. 201) initially began on March 26, 1971, when a pizza parlor proprietor was killed during an attempted robbery in Rochester, New York. Then in September of the same year, the Rochester police department received an implicated suspect for the murder from an incarcerated informant. However, the police chief of the department determined that the information provided was insufficient to acquire a warrant in order to arrest the suspect. Despite this, the police chief ordered officers to dispatch to the suspect’s residence and deliver him to the station for questioning. When he was retrieved, he was notified by the officers that if he attempted to leave, he would be physically restrained, although he was not officially placed under arrest. Upon arrival, he was read his Miranda rights, and after waiving his right to counsel, the petitioner incriminated himself in the crimes through sketches and statements he made to officers. The state court trial before a jury concluded that the petitioner’s statements were voluntary under the standards of the Fifth Amendment, and the recital of the Miranda rights was sufficient to justify the officers’ actions from the protections of the Fourth Amendment. The New York Court of Appeals instructed the trial court to further investigate the results of the petitioner’s detention, and the court awarded the petitioner’s motion to suppress his previous statements. Both the New York Court of Appeals (Fourth Division) and the Appellate Court of the New York Supreme Court reversed with this decision, finding that the officers’ reasonable suspicion of the petitioner was sufficient to not garner a warrant from any judicial authority. The United States Supreme Court subsequently granted certiorari. The justices, when determining the result of Dunaway v. New York case, utilized numerous precedents related to the warrant-less seizure of individuals, including; Terry v. Ohio, which determined that frisks are less intrusive than arrests for suspicion based upon probable cause, Brown v. Illinois, which a suspect made incriminating statements after being informed of their Miranda rights after an arrest on unsubstantiated probable cause, Brinegar v. United States, which afforded protection through reasonable probable cause under the Fourth Amendment, Adams v. Williams, which granted Fourth Amendment protection against weapons frisks, Pennsylvania v. Mimms, which a frisk for weapons was justified if a “bulge” appeared on an individual’s jacket, United States v. Martinez-Fuerte, which allowed predetermined checkpoints in fixed locations for vehicle checks seeking illegal immigrant, Davis v. Mississippi, which found that fingerprints acquired from suspect detained without probable cause was to be dismissed in court, and when determining the constitutionality of the officer’s actions in conjunction with the acquisition of the sketches and statements provided by the suspect, the court referred to three cases; Wong Sun v. United States, Nardone v. United States and Silverthorne Lumber Co. v. United States. The Supreme Court ruled 6-2 in favor of the petitioner (as Justice Powell excluded himself from deliberations in this case), determining that the Rochester police department violated the guaranteed protections of the Fourth and Fifth Amendments by arresting the petitioner without probable cause, the petitioner’s involuntary seizure by authorities violated the Fourth Amendment because of the lacking probable cause, that Terry v. Ohio was sufficient to effectively determine the parameters of this case and that under the parameters of Brown v. Illinois, the petitioner’s initial confession under an illegal arrest was inconsiderable in court because of the circumstances involved in his apprehension and the misconduct of officers. Therefore, the Court reversed the lower court’s decision. Justice Brennan delivered the majority opinion of the Court, which Justices Stevens, Blackmun, Marshall, White and Stewart joined. Brennan determined that in this case the petitioner was “seized” under the guidelines of the Fourth Amendment as he was involuntarily brought to the police station by officers without justifiable probable cause. Also, he found that the requirement of probable cause required by numerous precedents of previous courts is an absolute under the terms and language of the Fourth Amendment. This probable cause doesn’t solely rely on whether or not the individual was officially “arrested” before the interrogation process, and the fact that the individual implicates himself in the investigation does not merit a justifiable arrest because of the absence of probable cause. Most notably, the proper “balancing” in the judgment of police officers when interpreting the validations for a probable cause arrest or seizure must be determined by an outside viewer, in this case a court of justice, as reasonable beyond a doubt. Brennan reiterated the conclusions determined by the majority of the court that the petitioner’s detention and interrogation grossly invaded his basic rights protected by the Fourth Amendment and the Rochester police partook in an illegal arrest when refusing to gather a warrant before detaining the petitioner. Justice White, while joining the majority, articulated his own concurring opinion concerning this case. In his opinion, White emphasized the actions of the officers, concluding that while not officially labeled as an “arrest” by the Rochester police, the petitioner’s detention was in no doubt an arrest, which would require a level of probable cause on part of the officers. Justice Stevens, also joining the majority while writing his own concurring opinion, added that the flagrant misconduct of law enforcement officials, in not only the arrest of the petitioner but his interrogation, was an exploitation of his Constitutional rights. Stevens seemed disgusted by the subjective actions of the police department and officers, calling for exclusionary rules to create objective criteria in cases involving arrests without proper warrants or probable cause. Justice Rehnquist, joined by Chief Justice Burger joined, wrote the dissenting opinion of the court. He found that the Supreme Court’s majority decision to concur with the conclusions of the trail court was unfounded, because the court failed to correctly apply the precedent set forth in the Terry case in defining a “seizure”. Rehnquist wrote that the Court based its notion of “seizure” on the case that the petitioner was simply held in temporary custody. He continues with his disagreement over the Court’s decision in that the petitioner was involuntarily held without probable cause, and the defaming statements and sketches he made while detained should not be suppressed under the protections of the Fourth Amendment. Rehnquist also disagrees with the Court’s ruling concerning the conduct of the officers, finding that the recital of the Miranda rights to a suspect is sufficient to ensure that the statements of a suspect is the voluntary free-will of the suspect and therefore unprotected by the self-incrimination shielded inherent in the Fifth Amendment. Thusly, Rehnquist and Chief Justice Berger’s opinions sided with the decision of the Appellate Division of the Supreme Court of New York. Read More