442 U.S. 200 (1979)
On March 26, 1971, the proprietor of a pizza parlor in Rochester, New York, was killed during an attempted robbery.1 On August 10, 1971, Detective Anthony Fantigrossi learned of a possible lead implicating petitioner Irving Dunaway in the crime from an informant.2 Fantigrossi questioned a jail inmate but obtained no information sufficient to secure a warrant for Dunaway's arrest.3
Nevertheless, on the morning of August 11, 1971, three detectives located Dunaway at a neighbor's house and took him into custody.4 Although not told he was under arrest, Dunaway would have been physically restrained if he had attempted to leave.5 He was driven to police headquarters in a police car and placed in an interrogation room.6
After receiving Miranda warnings, Dunaway waived his right to counsel and made statements and drew sketches that incriminated him in the crime.7 He was then formally arrested and charged with murder and attempted robbery.8
Dunaway's motion to suppress the statements and sketches was denied at trial, and he was convicted by a jury.9 Following initial affirmances and a remand from the Supreme Court in light of Brown v. Illinois, the County Court found the detention illegal and granted the suppression motion, but the Appellate Division reversed that determination.10 The New York Court of Appeals dismissed Dunaway's application for leave to appeal.11
Whether the police violated the Fourth and Fourteenth Amendments when, without probable cause to arrest, they took petitioner into custody, transported him to the police station, and detained him there for interrogation?12
The Fourth Amendment requires probable cause to justify seizures of the person that amount to traditional arrests or equivalent custodial detentions for interrogation at a police station.13 The narrow Terry exception permits only brief, on-scene investigative stops based on reasonable suspicion to confirm or dispel suspicion of criminal activity and does not authorize stationhouse detention on less than probable cause.14
Yes. The detectives took Dunaway from a neighbor's house without a warrant or probable cause, transported him in a police car to headquarters, and placed him in an interrogation room where he would have been physically restrained had he attempted to leave.15 This seizure was indistinguishable from a traditional arrest because Dunaway was not questioned briefly at the scene, was never told he was free to go, and was held for custodial interrogation based solely on an unverified informant's tip.16 The Terry line of cases authorizes only limited intrusions for quick investigation, not the prolonged stationhouse detention that occurred here.17
The police violated the Fourth and Fourteenth Amendments.18
Related opinions on this issue
Joined by Powell, J.
Justice White joined the opinion of the Court to emphasize that the Terry exception is narrow and does not extend to stationhouse detention for prolonged questioning.19 He stressed that the police may not detain a suspect for custodial interrogation on less than probable cause.20 As our prior cases hold, the key principle of the Fourth Amendment is reasonableness—the balancing of competing interests.21
For White, the conduct here was similar enough to an arrest that the normal level of probable cause was required before privacy and personal security interests could be overridden.22
Justice Powell joined the opinion of the Court and Justice White's concurrence.23 He underscored that the Fourth Amendment prohibits the kind of seizure that occurred when Dunaway was taken into custody without probable cause and transported to the station for interrogation.24 Powell viewed the detention as crossing the line from a permissible Terry stop into a full arrest-like seizure.25
His position reinforces the majority's holding that such custodial detention requires probable cause under the Fourth Amendment to protect individual privacy interests.26
Justice Stevens joined the Court's opinion and added a comment on factors relevant to determining whether a confession was obtained by exploitation of an illegal arrest.27 He explained that the temporal relationship between the arrest and the confession may be ambiguous because a prolonged detention without intervening circumstances may constitute a more serious exploitation than a short one.28 Stevens further noted that the flagrancy of official misconduct is relevant only insofar as it tends to motivate the defendant.29
He favored objective criteria for applying the exclusionary rule rather than subjective inquiries into an officer's good faith.30
Whether the connection between this unconstitutional police conduct and the incriminating statements and sketches obtained during petitioner's illegal detention was nevertheless sufficiently attenuated to permit the use at trial of the statements and sketches?31
Under Brown v. Illinois, Miranda warnings alone do not purge the taint of an illegal seizure for Fourth Amendment purposes.32 Courts must examine the temporal proximity between the illegal detention and the confession, the presence of any intervening circumstances, and the purpose and flagrancy of the official misconduct to decide whether the statements were obtained by exploitation of the illegality.33
No. Dunaway gave his statements and sketches within an hour of arriving at the station with no intervening events of significance, the detention was a purposeful expedition for evidence undertaken without probable cause, and the Miranda warnings by themselves were insufficient to attenuate the taint under the Brown factors.34 The close causal connection between the illegal seizure and the incriminating evidence requires suppression to serve the distinct policies of the Fourth Amendment.35
The statements and sketches must be suppressed.36
Related opinions on this issue
Joined by Burger, C. J.
Justice Rehnquist dissented on the ground that petitioner voluntarily accompanied the officers to the station and therefore was not seized within the meaning of the Fourth Amendment.37 He argued that the police acted in good faith under then-existing New York precedent permitting such detentions on less than probable cause.38 Rehnquist further contended that the Miranda warnings plus the voluntary nature of the statements sufficiently attenuated any taint under the Brown analysis.39
He argued that the purpose and flagrancy factor should receive the greatest weight when police have not acted in a flagrant manner.40
Chief Justice Burger joined Justice Rehnquist's dissent.41 He contended that the Court's decision unduly extends the exclusionary rule to suppress statements obtained after a valid Miranda waiver. Burger argued that the ruling hampers effective law enforcement by restricting legitimate investigative techniques without advancing significant Fourth Amendment values.
The police had acted reasonably on an informant's tip in investigating a serious unsolved crime, and the voluntary waiver broke any causal link to the detention. His position diverges from the majority by emphasizing practical needs of crime detection over rigid probable cause requirements in this context, and he would have affirmed the conviction.