People v. Harris, 141 A.D.3d 1024

Background

Police responded to a 7:30 a.m. disturbance and entered an unlocked apartment to stop a physical fight between two male residents; the aggressor was handcuffed and the victim seated on the couch.
Defendant exited a bathroom, sat on the couch when asked, and identified his wife as being in a locked back bedroom off the kitchen.
An officer performed a sweep of rooms opening directly into the living room, then knocked on the locked back-bedroom door, directed the wife to come out, smelled an unfamiliar chemical from the bedroom, entered the bedroom, lifted a shirt and observed a pot on a hotplate that he believed was a meth lab.
Investigators were called; after the bedroom discovery, occupants were frisked and an investigator questioned defendant in the living room without Miranda warnings, eliciting incriminating oral statements.
Defendant was then taken to the station, given Miranda warnings, and signed a written (Mirandized) statement. A warrant was later issued based on the bedroom observations and meth was seized.
County Court denied suppression; defendant pleaded guilty to a lesser count and was sentenced. On appeal the Appellate Division reversed suppression rulings and vacated the plea.

Issues

Issue	People’s Argument	Defendant’s Argument	Held
Were officers permitted to enter and search the locked back bedroom as a protective sweep?	Sweep justified by exigent entry plus observations in other bedrooms and proximity of back bedroom; officer smelled chemicals and heard movement.	No articulable facts supported belief someone dangerous was in that bedroom; sweep exceeded Buie limits.	Entry/search of bedroom exceeded protective-sweep scope; physical evidence from bedroom suppressed.
Could items observed in bedroom support issuance of a search warrant?	Observations from sweep provided probable cause for warrant.	Observations were tainted by unlawful sweep; warrant lacked lawful basis.	Evidence from unlawful bedroom entry could not form basis for the warrant; suppression required.
Were defendant’s oral statements in the apartment admissible (Miranda)?	Statements were voluntary and not custodial because defendant was not restrained and questioning was brief.	Atmosphere was police-dominated after discovery of meth lab; a reasonable person would not feel free to leave so Miranda required.	Oral statements at the apartment were custodial; failure to give Miranda required suppression.
Was the subsequent written, Mirandized statement admissible or attenuated from the Miranda violation?	Later warnings and change of location/staff break the chain; written statement admissible.	Written statement was product of a single continuous chain from unwarned interrogation.	People failed to show adequate break; written statement suppressed.

Key Cases Cited

Kentucky v. King, 563 U.S. 452 (warrantless entry exceptions and exigent-circumstances framework)
Brigham City v. Stuart, 547 U.S. 398 (officers may enter to render aid when they reasonably believe violence is occurring)
Maryland v. Buie, 494 U.S. 325 (scope and limits of protective sweeps)
United States v. Simmons, 661 F.3d 151 (2d Cir.) (discussing exigent-entry and protective-sweep principles)