People v. Quick, 52 N.Y.2d 1041 (1981)
A confession obtained during questioning of a defendant in custody on one charge must be suppressed in its entirety, even if it concerns an unrelated incident, where the questioning violates the defendant’s right to counsel.
Summary
The New York Court of Appeals held that a confession obtained from a defendant, who was in custody on one charge, must be suppressed in its entirety even if it relates to an unrelated crime. The defendant was arrested, arraigned, and held in custody. While in custody, police questioned him about the charge for which he was being held and also about an unrelated incident. The Court reasoned that since the questioning violated the defendant’s right to counsel under People v. Hobson, the entire confession, including the portion related to the unrelated incident, was inadmissible. The Court rejected the argument that the confession was spontaneous due to the defendant’s own remarks.
Facts
The defendant was arrested, arraigned, and held in custody on one charge. While in custody, police questioned the defendant not only about the charge for which he was being held, but also about a separate, unrelated incident. The questioning occurred while the defendant was in custody and without the presence of counsel.
Procedural History
The hearing court initially held that the defendant’s statement should be suppressed only insofar as it related to the charge for which the defendant was being held, citing People v. Hobson. The prosecution sought to admit the portion of the confession related to the unrelated incident. The case reached the New York Court of Appeals.
Issue(s)
Whether a confession obtained during questioning of a defendant in custody on one charge must be suppressed in its entirety if the questioning violates the defendant’s right to counsel, even if part of the confession concerns an unrelated incident.
Holding
Yes, because the questioning violated the defendant’s right to counsel; therefore, the entire confession, including the portion related to the unrelated incident, must be suppressed.
Court’s Reasoning
The Court of Appeals relied on People v. Rogers, which extended the protections established in People v. Hobson. The Court reasoned that once a defendant in custody is represented by counsel, or has invoked the right to counsel, they cannot be questioned in the absence of counsel. This rule applies even if the questioning pertains to an unrelated matter. The Court explicitly stated that the protections of People v. Hobson apply to cases on appeal at the time Hobson was decided. The Court rejected the prosecution’s argument that the confession was spontaneous, stating that the fact that the questioning was prompted by the defendant’s remarks did not render his answers spontaneous, citing People v. Tompkins. The court emphasized the prophylactic nature of the Hobson rule, designed to safeguard the attorney-client relationship and prevent police overreach. The court found no merit to the prosecutor’s argument that People v. Rogers should not be applied retroactively, noting that Rogers was based on People v. Hobson, which has been applied to cases on appeal at the time the case was decided. Judge Jasen concurred on constraint of People v Rogers.