Saturday, November 2, 2013

Dunaway v. New York case brief

Dunaway v. New York case brief summary
442 U.S. 200 (1979)

The court granted certiorari on a decision from the Appellate Division, Supreme Court of New York, Fourth Judicial Department for clarifying the Fourth Amendment's requirements as to the permissible grounds for custodial interrogation. Petitioner had been convicted of murder.

A murder occurred during an attempted robbery. An informant supplied a possible lead that implicated petitioner. The police questioned the informant but did not have enough information to get a warrant for petitioner's arrest. The police located petitioner and took him into custody. Although he was not told he was under arrest, he would have been restrained if he had attempted to leave. He was taken to the police headquarters, and questioned after being given Miranda warnings. Petitioner waived his right to counsel and made incriminating statements.

  • On appeal, the Court held that the detention for custodial interrogation intruded on the interests protected by the Fourth and Fourteenth Amendment of the constitution and held that the police violated the constitution when, without probable cause, they seized petitioner for interrogation. 
  • The Court held that while proper Miranda warnings were given and petitioner's statements were "voluntary" for purposes of the Fifth Amendment, they were inadmissible since no intervening events broke the connection between petitioner's illegal detention and his confession.


The Court reversed the lower court's judgment that convicted defendant of murder because the police violated the Fourth Amendment and the Fourteenth Amendment by illegally detaining petitioner for interrogation without probable cause.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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