People v. Green, 46 N.Y.2d 974 (1979)
A defendant has the right to fully explore the issue of probable cause for their arrest during a suppression hearing to challenge the admissibility of statements obtained as a result of that arrest.
Summary
The New York Court of Appeals held that a defendant’s motion to suppress confessions should not have been denied because the trial court improperly restricted the defendant’s ability to cross-examine police officers regarding the probable cause for his arrest. The Court found that statements obtained as a result of an unlawful arrest or detention are inadmissible. The defendant was entitled to a new suppression hearing where he could fully explore the legality of his arrest, and his guilty plea was vacated.
Facts
Two police officers responded to a report of child molestation and went to the alleged victim’s home. After speaking with the victim and her mother, they proceeded to the defendant’s home, where they informed him that his stepdaughter had accused him of rape. The defendant made no response and was then advised of his rights, frisked, handcuffed, and taken to police headquarters. At headquarters, he was again informed of his rights and made inculpatory admissions, both orally and in a signed statement, after waiving his right to an attorney on three separate occasions.
Procedural History
The defendant moved to suppress his admissions, arguing they were the result of an unlawful arrest. The trial court limited the scope of questioning to the voluntariness of the statements, finding that the defendant had waived his rights and confessed voluntarily, and denied the motion. The defendant then pleaded guilty to attempted rape in the first degree and appealed the denial of his motion to suppress. The Appellate Division affirmed. The case then went to the New York Court of Appeals.
Issue(s)
Whether the trial court erred in restricting the defendant’s ability to cross-examine police officers regarding the probable cause for his arrest during the suppression hearing, thus improperly denying his motion to suppress his confessions.
Holding
Yes, because statements obtained by exploitation of unlawful police conduct or detention must be suppressed, and the defendant was not given adequate opportunity to challenge the legality of his arrest.
Court’s Reasoning
The Court of Appeals reasoned that the Fourth Amendment requires the suppression of statements obtained through the exploitation of unlawful police conduct or detention. The Court emphasized that a suppression court must allow inquiry into the propriety of the police conduct. The People have the burden of establishing probable cause for the arrest or detention, and the defendant must be given an opportunity to fully investigate the circumstances of the arrest. The court found that the trial court’s restriction on cross-examination prevented the defendant from adequately challenging the prosecution’s assertion of probable cause. Because the defendant was not afforded a full opportunity to litigate the issue of probable cause, the denial of the suppression motion was improper. The Court remanded the case for a new hearing on the issue of probable cause, vacated the defendant’s guilty plea, and restored the suppression motion to pending status. The court cited People v. Wise, 46 NY2d 321, 329 stating it is “incumbent upon the suppression court to permit an inquiry into the propriety of the police conduct”. The court also noted, “Unless the People establish that the police had probable cause to arrest or detain a suspect, and unless the defendant is accorded an opportunity to delve fully into the circumstances attendant upon his arrest or detention, his motion to suppress should be granted”.