People v. Parris, 83 N.Y.2d 342 (1994)
A spontaneous statement made to law enforcement requires notice under CPL 710.30(1)(a), and an arrest requires probable cause based on reliable information, not unsubstantiated hearsay or rumor.
Summary
Gwendolyn Parris was convicted of criminally negligent homicide for the stabbing death of her cousin. The Court of Appeals addressed whether her initial spontaneous statement to police was admissible without prior notice and whether subsequent statements should have been suppressed as fruits of an unlawful arrest. The Court held that notice was required for the initial statement. Further, the Court found that the arrest was not based on probable cause. The case was remitted to the Supreme Court to determine if Parris’s detention was a lawful temporary detention, and if not, whether subsequent statements were sufficiently attenuated from the illegal detention to be admissible.
Facts
After a fatal stabbing, Detective Wasserman learned from the victim’s family that the defendant, Parris, had inflicted the wound. At the scene, anonymous informants told Detective O’Brien that “Gwenny” stabbed the victim. Parris arrived at the scene and was identified as “Gwenny.” She was placed in a police car, where she spontaneously stated that she stabbed the victim. Later, at the precinct, after receiving Miranda warnings, Parris made three more statements: a written statement to Detective Wasserman, another to Detective Sanchez, and a videotaped statement to an Assistant District Attorney.
Procedural History
The People notified Parris of their intent to offer her statements at trial, but the notice omitted her initial statement in the police car. Parris moved to suppress the statements, arguing an unlawful arrest and an involuntary waiver of rights. The trial court denied the motion, finding probable cause for the arrest and deeming the initial statement spontaneous and thus not requiring notice. The Appellate Division affirmed the conviction. The Court of Appeals granted leave to appeal.
Issue(s)
1. Whether the People were required to provide notice under CPL 710.30(1)(a) of their intent to offer Parris’s initial, spontaneous statement to police.
2. Whether Parris’s statements to the police and the Assistant District Attorney should have been suppressed as the fruits of an arrest made without probable cause.
Holding
1. Yes, because CPL 710.30(1)(a) requires notice whenever the prosecution intends to offer at trial evidence of a statement made by a defendant to a public servant, regardless of its apparent spontaneity.
2. No, not definitively; the case is remitted to determine whether the police action constituted an arrest or a temporary detention based on reasonable suspicion, and whether any taint from the initial illegality was attenuated.
Court’s Reasoning
The Court reasoned that CPL 710.30(1)(a) mandates notice for any statement made to law enforcement that the prosecution intends to use at trial, to allow the defendant to challenge its voluntariness. Even a spontaneous statement requires notice because “the defendant had the right to have a court review the circumstances under which the statement was given and to determine its voluntariness.” Quoting People v. Greer, 42 N.Y.2d 170, the court stated that even if the statement was voluntary, preclusion is required if the People fail to give the required notice.
Regarding probable cause, the Court noted that probable cause requires information sufficient to support a reasonable belief that an offense has been or is being committed by the suspect, citing People v. Hicks, 68 NY2d 234, 238. While hearsay can provide probable cause, the informants must be reliable and have a basis for their knowledge. Here, the anonymous tips and family statements lacked a sufficient basis of knowledge, constituting mere “suspicion or ‘rumor’.”
The Court remitted the case to determine whether the initial detention was an arrest or a lawful temporary detention based on reasonable suspicion under People v. Hicks. If the detention was unlawful, the court must determine if the subsequent statements were attenuated from the illegal detention, guided by People v. Rogers, 52 NY2d 527. If the statements were not sufficiently attenuated, they must be suppressed, potentially requiring a new trial. If the later statements are admissible, the conviction should be reviewed under a harmless error analysis, citing People v. Crimmins, 36 NY2d 230.
The Court upheld the trial court’s admission of evidence of a prior uncharged crime, as it was central to establishing the decedent’s conflict with the defendant.