48 N.Y.2d 256 (1979)
A warrantless arrest in a suspect’s home is permissible if there is probable cause, and statements made following the arrest are admissible if knowingly and voluntarily obtained; severance motions are properly denied if the co-defendant testifies, obviating Bruton concerns.
Summary
Knapp was convicted of second-degree murder for the homicide of a service station attendant. Prior to trial, he unsuccessfully sought to suppress statements and physical evidence obtained from his home and car, arguing his warrantless arrest was unlawful and his statements were involuntary. He also sought a severance, which was denied. The Court of Appeals affirmed his conviction, holding that the warrantless arrest was proper given probable cause, his statements and consent to search were voluntary, and the co-defendant’s testimony cured any Bruton violation. This case clarifies the permissible scope of warrantless home arrests and the admissibility of subsequent statements.
Facts
Anthony Caputo, a service station attendant, was murdered. Knapp and Frederick Cunningham were arrested and charged with the crime. Prior to trial, Knapp moved to suppress statements he made to police and physical evidence seized from his home and car, alleging an unlawful warrantless arrest and involuntary statements. He also sought to sever his trial from Cunningham’s. The suppression motion and severance motion were denied.
Procedural History
The trial court convicted Knapp of two counts of second-degree murder. Knapp appealed the conviction, arguing the denial of his suppression and severance motions were erroneous. The Appellate Division affirmed the trial court’s decision. Knapp then appealed to the New York Court of Appeals.
Issue(s)
1. Whether a warrantless arrest in the defendant’s home is permissible when police have probable cause.
2. Whether the defendant’s statements and consent to search were knowingly and voluntarily obtained.
3. Whether the denial of the defendant’s motion to sever was erroneous in light of Bruton v. United States.
Holding
1. Yes, because in the absence of any contention that the police lacked probable cause to arrest, the warrantless arrest at the defendant’s home was proper.
2. Yes, because the record supports the lower courts’ findings that the statements and consent to search were knowingly and voluntarily obtained.
3. No, because any objection based on Bruton v. United States was obviated when the co-defendant testified.
Court’s Reasoning
The Court of Appeals affirmed the lower courts’ decisions. Regarding the warrantless arrest, the court cited People v. Payton, stating that in the absence of a challenge to probable cause, a warrantless home arrest is permissible. The court also found that the record contained sufficient support for the hearing court’s finding, affirmed by the Appellate Division, that Knapp’s statements and consent to search were knowingly and voluntarily obtained, citing People v. Glass. Finally, the court addressed the severance issue, noting that the co-defendant Cunningham’s testimony negated any potential Bruton violation. The court referenced People v. Anthony, stating that the Bruton rule, which prohibits the admission of a non-testifying co-defendant’s confession implicating the defendant, does not apply when the co-defendant testifies. The court emphasized that the lower courts made factual findings, supported by the record, regarding the voluntariness of Knapp’s statements and consent, and the Court of Appeals deferred to those findings. The court focused on established precedent, emphasizing that its role is not to re-weigh the evidence but to determine if there was sufficient support for the lower courts’ conclusions. There were no dissenting or concurring opinions.