Cox v. State case brief
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696 N.E.2d 853
CASE SYNOPSIS: The Madison Superior
Court (Indiana) convicted the defendant, after a jury trial, of
murder and sentenced him to life imprisonment. The defendant appealed
the conviction.
FACTS: After his conviction for murder, the defendant contended that his warrantless arrest violated the Fourth and Fourteenth Amendments to the United States Constitution because the police unconstitutionally crossed the threshold of his home by opening the screen door, forcibly prevented him from closing the front door, and reached into the house to pull him out. He also contended that his subsequent confession should have been suppressed under the fruit of the poisonous tree doctrine.
HOLDING:
The court held even if the arrest was a violation of the federal constitution, the statement was admissible under the rule that where the police had probable cause to arrest a suspect, the exclusionary rule did not bar the state's use of a statement made by the defendant outside of his home, even though the statement was taken after the arrest made in the home was illegal.
ANALYSIS:
Because the defendant made his statement outside of his home following the alleged violation, the exclusionary rule did not bar its admission. The court found that the police had probable cause to arrest the defendant when they went to his house, without a warrant, to question him for the shooting.
CONCLUSION: The court affirmed the defendant's conviction and sentence.
FACTS: After his conviction for murder, the defendant contended that his warrantless arrest violated the Fourth and Fourteenth Amendments to the United States Constitution because the police unconstitutionally crossed the threshold of his home by opening the screen door, forcibly prevented him from closing the front door, and reached into the house to pull him out. He also contended that his subsequent confession should have been suppressed under the fruit of the poisonous tree doctrine.
HOLDING:
The court held even if the arrest was a violation of the federal constitution, the statement was admissible under the rule that where the police had probable cause to arrest a suspect, the exclusionary rule did not bar the state's use of a statement made by the defendant outside of his home, even though the statement was taken after the arrest made in the home was illegal.
ANALYSIS:
Because the defendant made his statement outside of his home following the alleged violation, the exclusionary rule did not bar its admission. The court found that the police had probable cause to arrest the defendant when they went to his house, without a warrant, to question him for the shooting.
CONCLUSION: The court affirmed the defendant's conviction and sentence.
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