68 N.Y.2d 952 (1986)

The rule established in Payton v. New York, prohibiting warrantless arrests inside a home absent exigent circumstances, is not violated when police, without entering, direct a suspect to exit their home and then arrest them based on probable cause.

Summary

The New York Court of Appeals affirmed the defendant’s conviction, holding that the police did not violate the Payton rule when they directed the defendant to exit his home and arrested him based on probable cause, even without a warrant. The Court emphasized that the key concern of Payton is the unsupervised invasion of privacy within a home. Since the police never crossed the threshold before the arrest, the Payton rule was not triggered. The subsequent entry into the home to arrest an accomplice, even if potentially unlawful, did not warrant reversing the defendant’s conviction because the admission of the gun found during that entry was harmless error.

Facts

Police officers approached the defendant’s home. One officer observed the defendant peeking through a window. The police directed the defendant to come outside. Although several officers were present and at least one had his gun drawn, there was no evidence the defendant was threatened or saw the gun before exiting. Upon exiting, the police arrested the defendant, for whom they had probable cause. After the arrest, police entered the home and arrested an alleged accomplice, Winzell Beckett, finding a gun inside.

Procedural History

The trial court convicted the defendant. The Appellate Division affirmed the conviction. The case then went to the New York Court of Appeals.

Issue(s)

1. Whether directing a suspect to exit their home for arrest, based on probable cause but without a warrant, violates the Fourth Amendment protection against warrantless entry established in Payton v. New York?

2. Whether the subsequent warrantless entry into the defendant’s home to arrest an accomplice and seize evidence (a gun) warrants reversing the defendant’s conviction, considering the admission of that gun at trial?

Holding

1. No, because the Payton rule addresses the unsupervised invasion of privacy within a home, and the police did not cross the threshold before arresting the defendant.

2. No, because even if the entry was unlawful under Steagald v. United States, the admission of the gun was harmless error beyond a reasonable doubt.

Court’s Reasoning

The Court reasoned that the core principle of Payton v. New York (445 US 573) is to prevent the unsupervised invasion of a citizen’s privacy in their home. The Court emphasized that “[n]either the letter nor the spirit of the Payton rule was violated here, where the police approached defendant’s home, saw defendant, whom they did not know, peeking through a window and directed him to come out.” Because the police did not physically enter the home before the arrest, the defendant’s privacy within the home was not unlawfully breached at that point. The Court distinguished this situation from a scenario where police cross the threshold to effect an arrest. Regarding the subsequent entry to arrest Beckett, the Court acknowledged potential issues under Steagald v. United States (451 US 204), which concerns the rights of third parties within a home. However, it deemed the admission of the gun found during that entry as harmless error, as it did not significantly impact the outcome of the defendant’s trial. The Court therefore declined to reverse the conviction based on this secondary issue, focusing on the primary concern of whether the initial arrest violated Payton.