People v. Harris, 48 N.Y.2d 208 (1979)
Statements obtained during a custodial interrogation are inadmissible if Miranda warnings were not administered, and a guilty plea entered after the erroneous denial of a motion to suppress such statements must be vacated unless it can be said with certainty that the error played no part in the defendant’s decision to plead guilty.
Summary
Harris pleaded guilty to second-degree robbery. He appealed, arguing that the trial court erred by failing to suppress (1) a potential in-court identification, (2) statements he made to police without Miranda warnings, and (3) sticks seized from him. The New York Court of Appeals reversed, vacated the plea, and remanded. The Court held that Harris’s statements should have been suppressed because they were the product of a custodial interrogation conducted without Miranda warnings. Although the Court upheld the denial of the motion to suppress the sticks, the improperly admitted statements require allowing the defendant to reconsider his guilty plea.
Facts
On December 30, 1974, three men, each carrying a stick, forced their way into Mrs. Turner’s home and robbed her. About 30 minutes later, Mrs. Turner’s son, Police Officer Clark, and two other officers stopped three men, two of whom were carrying a television set, and one of whom (Harris) was carrying two gray sticks. The two men carrying the television dropped it and fled. Officer Clark detained Harris and questioned him about the other two men and the television set without administering Miranda warnings. Harris stated he only knew one of the men by the name of “Billy” and did not know where the television came from. Officer Clark later learned his mother had been robbed and the television set taken from the men was hers. Mrs. Turner subsequently identified Harris in a photo array and a lineup.
Procedural History
Harris was charged with robbery. He moved to suppress his statements, the sticks, and any identification by Mrs. Turner. After a combined Wade-Mapp-Huntley hearing, the trial court denied the motion to suppress. Harris then pleaded guilty. The Appellate Division affirmed the conviction. Harris appealed to the New York Court of Appeals.
Issue(s)
1. Whether the trial court erred in failing to suppress statements made by Harris to the police when he was in custody but had not been given Miranda warnings.
2. Whether the trial court erred in failing to suppress the sticks taken from Harris on the night of the crime.
Holding
1. Yes, because the statements were obtained during a custodial interrogation without Miranda warnings, and their admission was prejudicial to the defendant.
2. No, because the officers had reasonable suspicion to temporarily detain Harris and take possession of the sticks for their own protection during questioning.
Court’s Reasoning
The Court reasoned that Harris was subjected to custodial interrogation without being advised of his Miranda rights. The Court applied the standard of whether a reasonable person, innocent of any crime, would have felt free to leave. It determined that Harris was “in custody” when he was detained by officers, placed in the patrol car, and questioned. Because Harris’s statements were made without Miranda warnings, they should have been suppressed.
The Court acknowledged the difficulty in determining whether an erroneous pretrial ruling contributed to a defendant’s decision to plead guilty, referencing People v. Grant, 45 N.Y.2d 366, 379. It noted that “when a conviction is based on a plea of guilty an appellate court will rarely, if ever, be able to determine whether an erroneous denial of a motion to suppress contributed to the defendant’s decision, unless at the time of the plea he states or reveals his reason for pleading guilty.” Because a jury could reasonably interpret Harris’s statement as inculpatory, it could not be said with certainty that the erroneous ruling played no part in Harris’s decision to plead guilty. Therefore, the plea must be vacated.
Regarding the sticks, the Court held that the officers had reasonable suspicion to believe Harris was involved in a felony or misdemeanor, justifying the temporary detention and seizure of the sticks for the officers’ safety. The Court cited Terry v. Ohio, 392 U.S. 1, noting that the Constitution does not require probable cause for such an action. CPL 140.50 authorizes temporary detention based on reasonable suspicion. Therefore, the denial of the motion to suppress the sticks was proper. The failure to return them after questioning was a statutory violation but not a constitutional one, and did not warrant suppression.