People v. Bethea, 67 N.Y.2d 364 (1986)

Under the New York State Constitution, subsequent confessions made after Miranda warnings are inadmissible if they are the product of a continuous chain of events initiated by an unwarned custodial interrogation.

Summary

Bethea was stopped and questioned by police officers who suspected him of attempted burglary. After finding a revolver in his bag, officers arrested him. During transport to the precinct, Bethea made incriminating statements without having been read his Miranda rights. At the precinct, after receiving Miranda warnings, he repeated the statements. The New York Court of Appeals held that the second statement was inadmissible because it was part of a continuous interrogation that began before Miranda warnings were given, thus reaffirming the rule in People v. Chapple as a matter of state constitutional law. The court emphasized that Article I, § 6 of the NY Constitution would be undermined if police could circumvent Miranda by intentionally eliciting unwarned statements followed by warned confessions.

Facts

1. Police officers stopped Bethea and a companion based on a tip about an attempted burglary involving men matching their descriptions.
2. An officer, with his gun drawn, questioned Bethea and his companion about their activities and the contents of Bethea’s bag.
3. The officers discovered a revolver in Bethea’s bag, leading to the arrest and search of Bethea.
4. A pair of handcuffs and marihuana were found on Bethea during the search.
5. While being transported to the precinct, Bethea was asked where he got the gun and he made incriminating statements without being advised of his Miranda rights.
6. At the precinct, Bethea was given Miranda warnings and repeated the incriminating statements.

Procedural History

1. The trial court suppressed Bethea’s initial unwarned statement but admitted the physical evidence (gun, handcuffs, marihuana) and the second statement made after Miranda warnings.
2. The Appellate Division affirmed the trial court’s decision.
3. The case was appealed to the New York Court of Appeals.

Issue(s)

Whether a statement made after Miranda warnings is admissible when it is a repetition of a statement made during a prior custodial interrogation without Miranda warnings, and the interrogations are part of a single continuous chain of events.

Holding

No, because under the New York State Constitution, a subsequent confession is inadmissible if it is the product of a continuous chain of events initiated by an unwarned custodial interrogation, and the warnings administered before the later statements were insufficient to protect his rights.

Court’s Reasoning

The Court of Appeals relied on its prior decision in People v. Chapple, which held that statements obtained as a result of a continuous custodial interrogation are inadmissible, even if Miranda warnings are given before subsequent statements. The court reasoned that allowing the admission of the second statement would undermine the protections against self-incrimination guaranteed by the New York State Constitution. The court emphasized the importance of deterring police from intentionally circumventing Miranda by first obtaining an unwarned confession and then securing a warned confession. The court distinguished the U.S. Supreme Court case, Oregon v. Elstad, noting any inconsistency with Chapple, the court adhered to Chapple as a matter of state constitutional law. The court noted “the mandate of NY Constitution, article I, § 6 that ‘[n]o person * * * shall * * * be compelled in any criminal case to be a witness against himself’ would have little deterrent effect if the police know that they can as part of a continuous chain of events question a suspect in custody without warning, provided only they thereafter question him or her again after warnings have been given.” Because the arresting officer’s testimony established a close sequence between the unwarned statement in the van and the repetition at the precinct, the second statement should have been suppressed.