People v. Catanzaro, 17 N.Y.2d 171 (1966)

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The use of reasonable force to subdue a suspect during arrest does not automatically render statements made during or immediately after the arrest involuntary and inadmissible; the statements’ voluntariness depends on the totality of the circumstances.

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Summary

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Catanzaro was convicted of felony murder. Following a Supreme Court remand after Jackson v. Denno, a Huntley hearing was held to determine the voluntariness of his statements. Catanzaro argued that statements made during his arrest and later at the police station were involuntary due to police brutality. The trial court found the statements voluntary. The New York Court of Appeals affirmed, holding that the use of reasonable force during an arrest does not automatically invalidate subsequent statements, particularly when the statements are spontaneous and appear to be an attempt to exculpate oneself. The court emphasized that the focus is on whether impermissible methods were used to obtain the confession.

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Facts

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Catanzaro was a suspect in the killing of a United Parcel truck driver. Detectives found him at a hotel. Upon his return, officers followed him and accosted him in front of his room. When Catanzaro reached for a package under his arm, officers grabbed him, and a struggle ensued. The package tore open, revealing a loaded gun. An officer yelled, “I have the gun. I have the murder weapon.” Catanzaro blurted out, “No, no, I was only driving the car. I didn’t do it. I didn’t do it. The kid did it.” He also stated the murder weapon was a .22 and the “kid” used it. After being told he would