People v. Arnau, 58 N.Y.2d 27 (1982)
Evidence seized pursuant to a valid search warrant, based on information obtained independently of an illegal entry, is admissible despite the prior illegality if there is no causal connection between the illegal entry and the discovery of the evidence.
Summary
This case addresses whether evidence seized under a valid search warrant should be suppressed because police officers illegally entered the premises before obtaining the warrant. The Court of Appeals held that the evidence was admissible because the warrant was based on information obtained independently of the illegal entry, and the entry did not contribute to the warrant’s issuance or the discovery of the evidence. The court emphasized that the exclusionary rule should not apply when the evidence is obtained lawfully through an independent source, even if the police committed an unrelated wrong.
Facts
An undercover officer purchased cocaine from Arnau at his apartment. The officer observed a large quantity of narcotics within the apartment. Based on this information, a decision was made to immediately enter and secure the apartment. Officers entered Arnau’s apartment without a warrant, arrested him, and secured the premises. No search for evidence occurred during this initial entry. Subsequently, officers obtained a search warrant based solely on the undercover officer’s observations. The affidavit supporting the warrant made no mention of the initial entry. After obtaining the warrant, officers searched the apartment and discovered cocaine, marihuana, and drug paraphernalia.
Procedural History
Arnau was charged with multiple drug offenses. He moved to suppress the evidence seized during the search. The trial court denied the motion. The Appellate Division reversed, granted the motion to suppress, and remitted the case. The People appealed to the Court of Appeals.
Issue(s)
Whether evidence seized pursuant to a valid search warrant, obtained after an illegal entry but based solely on information from an independent source predating the entry, must be suppressed.
Holding
No, because the evidence was obtained through a source independent of the illegal entry, and the entry did not contribute to the warrant’s issuance or the discovery of the evidence.
Court’s Reasoning
The Court of Appeals reasoned that the exclusionary rule, designed to deter illegal police conduct, should not apply when the evidence is obtained through an independent source. The court invoked the “independent source rule,” derived from Silverthorne Lumber Co. v. United States, stating that illegally obtained facts do not become “sacred and inaccessible” if knowledge of them is gained from an independent source. The court emphasized that the defendant bears the burden of showing a causal connection between the illegal police conduct and the seizure of the evidence. Here, the valid search warrant was based entirely on the undercover officer’s observations, which occurred before and independently of the illegal entry. The court rejected the argument that securing the apartment constituted an automatic seizure of everything inside. The court stated, “It is one thing to say that officers shall gain no advantage from violating the individual’s rights; it is quite another to declare that such a violation shall put him beyond the law’s reach even if his guilt can be proved by evidence that has been obtained lawfully.” The court found no indication that the warrant was tainted by the illegal entry or that the police exploited the entry to obtain evidence. Thus, the exclusionary rule was deemed inapplicable. The court also held that the 24-hour search warrant was valid given the circumstances. Finally, the court stated that suppressing lawfully seized evidence simply because of an unrelated police error would be inappropriate, as the exclusionary rule was not intended to cover such scenarios.