People v. Dunaway Case Brief

Summary of People v. Dunaway, 442 US 200(1979)

Facts: The respondent, was accused of murder. A police detective questioned a confidential informant and was told that Dunaway had committed the crime. The officer knew he did not have enough information to secure a warrant, but ordered other officers pick up Dunaway and bring him to police headquarters. Three officers located him at his neighbor’s home, searched him, placed him in a police car and transported him to the station house. There, he was placed in an interrogation room, Mirandized and interrogated. He was never told he was under arrest. Dunaway waived counsel, confessed and even drew sketches that incriminated him in the murder.

Issue: Was the search and detention a violation of the defendants 4th Amendment rights protecting him from unlawful searches and seizures?

Held: The US Supreme court overturned the verdict of the NY Court of Appeals and a new trial was ordered, excluding the evidence that was deemed unconstitutionally obtained.

Rationale: The US Supreme Court held that the initial seizure was a proper one under the 4th Amendment privilege of an officer to search a suspect for weapons or objects of potential harm. However, they ruled that the detention of the accused was unlawful. The 4th Amendment allows only brief questioning of the accused and must be conducted at the present location of the person when only reasonable suspicion is the catalyst. Furthermore, the subsequent involuntary transportation of the defendant was deemed unconstitutional as well, and all evidence obtained from it was obtained illegally.

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