S.D.N.Y.: Payton violation doesn’t require suppression of confession

Payton violation doesn’t require suppression of confession. United States v. Medina, 2014 U.S. Dist. LEXIS 65708 (S.D. N.Y. May 7, 2014):

Finally, even if a Payton violation had occurred, it would not warrant suppression of Medina’s post-arrest statements. The Supreme Court has “decline[d] to apply the exclusionary rule in this context because the rule in Payton was designed to protect the physical integrity of the home; it was not intended to grant criminal suspects … protection for statements made outside their premises where the police have probable cause to arrest the suspect for committing a crime.” New York v. Harris, 495 U.S. 14, 17, 110 S. Ct. 1640, 109 L. Ed. 2d 13 (1990). Accordingly, “where the police have probable cause to arrest a suspect, the exclusionary rule does not bar the … use of a statement made by the defendant outside of his home, even though the statement is taken after an arrest made in the home in violation of Payton.” Id. at 21.

Because the NYPD had probable cause to arrest Medina, the exclusionary rule would not apply to his post-arrest statements, even if a Payton violation had occurred. Accordingly, Medina’s post-arrest statements will not be suppressed on this basis.