38 N.Y.2d 813 (1975)
A confession obtained after an illegal detention may be inadmissible, even if Miranda warnings are given, if the confession is a product of that illegal detention.
Summary
The New York Court of Appeals reconsidered its prior affirmance of Dunaway’s conviction for felony murder and attempted robbery in light of Brown v. Illinois. The court found that Dunaway may have been illegally detained when police took him into custody without probable cause, and that the confession he subsequently gave, even after being read his Miranda rights, may have been inadmissible as a product of that illegal detention. The court remitted the case to the trial court for a hearing to determine whether the detention was supported by probable cause and, if not, whether the confession was tainted by the illegal arrest.
Facts
Two men committed an armed robbery at a pizza shop in Rochester, New York, during which the proprietor was shot and killed. Four months later, three police officers went to Dunaway’s home and asked him to come downtown to talk about “something.” The record did not indicate that the police had any reason to suspect him. At the police station, Dunaway was taken to an interrogation room, given Miranda warnings, and waived his right to counsel. He then made inculpatory statements and drew incriminating sketches.
Procedural History
Prior to trial, Dunaway moved to suppress the statements and drawings, arguing they were obtained during an illegal detention without probable cause. The trial court denied the motion, ruling that the statements were voluntary after proper Miranda warnings. The Appellate Division affirmed. The New York Court of Appeals initially affirmed the conviction. The Supreme Court of the United States remanded the case to the New York Court of Appeals for further consideration in light of Brown v. Illinois.
Issue(s)
1. Was Dunaway illegally detained when the police took him into custody?
2. If Dunaway was illegally detained, was his confession inadmissible as a product of that illegal detention, even though Miranda warnings were given?
Holding
1. The court did not make a determination on whether Dunaway was illegally detained, because the record was inadequate to support a determination of probable cause.
2. If there was an illegal detention, the court did not make a determination on whether Dunaway’s confession was inadmissible because the trial court needed to determine whether the confession was tainted by the illegal arrest.
Court’s Reasoning
The court emphasized that the trial court made no findings as to the nature of Dunaway’s detention or whether there was probable cause for it. The District Attorney conceded that the record was inadequate to support a determination of probable cause. The court stated, “accordingly, this case must be remitted to the Monroe County Court for a factual hearing and such other proceedings as may be necessary to determine the issues…and, in the event there was a detention and probable cause is not found for such detention, to determine the further question as to whether the making of the confessions was rendered infirm by the illegal arrest (see Brown v Illinois, 422 US 590, supra).” The court recognized that even though Miranda warnings were given, a confession could still be inadmissible if it was the product of an illegal arrest. This reflects the Supreme Court’s holding in Brown v. Illinois, which held that Miranda warnings alone do not dissipate the taint of an illegal arrest. The focus must be on whether the confession was obtained by exploitation of the illegal arrest.