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Dunaway v. New York | 442 U.S. 200 (1979)

The detectives finally had a lead in an unsolved crime. They picked up the suspect and brought him in for questioning, which led to a trial and a conviction. But they never had probable cause to arrest him in the first place, which is why the case of Dunaway versus New York ended up in front of the United States Supreme Court.

In March, two men conducted an armed robbery of a Rochester pizza parlor. One of them shot and killed the proprietor. The crime went unsolved for months. In August, an informant implicated Irving Dunaway in the crime, but didn’t provide enough information to justify the police getting a warrant to arrest Dunaway. Nevertheless, a detective sent three police officers to Dunaway’s home to ask him to come police headquarters. Dunaway wasn’t told that he was under arrest, but he was taken into custody, and the police would’ve restrained him if he’d tried to leave. At headquarters, the police placed him in an interrogation room and gave him his Miranda warnings. He waived the right to counsel and made an incriminating statement.

At trial, the court denied Dunaway’s motion to suppress his statement. A jury convicted Dunaway of felony murder and attempted robbery. The appellate division and the New York Court of Appeals affirmed. The United States Supreme Court vacated the judgment and remanded the case. The county court then granted Dunaway’s motion to suppress, but the appellate division reversed, holding that, even without probable cause, police may detain an individual for questioning if they have reasonable suspicion that he was involved in a crime and they question the defendant for a reasonable period of time under controlled conditions sufficient to protect his Fifth and Sixth Amendment rights. The New York Court of Appeals affirmed. The Supreme Court granted cert.

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