Summary of Dunaway v. New York

Citation: 442 U.S. 200

Relevant Facts: Several months after a pizza parlor owner was killed during an attempted robbery police receive a tip from an informant implicating Dunaway.  When a detective questioned the informant about the tip, he did not get enough information to secure an arrest warrant but nevertheless brought him in for questioning. Dunaway was told that he was not under arrest when he was brought in, but at the same time he was advised that he was not permitted to leave.  He was Mirandized as well as put in an interrogation room.  Dunaway waived his right to counsel and subsequently incriminated himself.

Dunaway moved to suppress his statements and the incriminating drawings he had made during the trial phase, but those motions were denied.  The state Appellate Division and Court of Appeals affirmed the denial without an opinion on the matter.  The Supreme Court heard the matter and vacated the judgment against Dunaway and remanded the case.

Issues:  The legal questions presented were whether the police violated Dunaway’s Fourth and Fourteenth Amendment rights when they took Dunaway into custody without probable cause, and then detained him for interrogation; and, whether there was a sufficient connection between the unconstitutional police conduct and the incriminating statements and sketches that were obtained during Dunaway’s detention that could still make their use permissible in court.

Holding: Yes and no.

Reasoning:  The Court reasoned that there was no reasonable evidence to conclude that Dunaway had not been seized, because the threat of physical restraint should he try to leave was so clear.  The Court also reasoned that Terry v. Ohio did not apply because the stop was not directly related to the threat or applicable charge as had been the case in Terry v. Ohio.

Dissent: Chief Justice Rehnquist dissented, arguing that Dunaway voluntarily went with the police, and that he was not unreasonably seized because the police did not use physical force against him.

Conclusion: This case was significant because it demonstrated the Court’s approach of balancing the states interests vs. those privacy interests of the arrested, particularly when stopped in a vehicle for a crime that has nothing to do with their stop, and is not supported by probable cause to search and seize.