State v. Brown, 14 A.3d 26

Bergen County police investigated a string of armed robberies and auto thefts in late 2004 and early 2005 involving multiple suspects.
Detective Coffey prepared five complaints seeking arrest for various offenses, listing Brown’s last known address at a girlfriend’s apartment; these complaints were not reviewed by a judge before arrest.
On January 1, 2005, police went to the girlfriend’s address; Brown fled from the apartment to the roof of an adjacent building after officers knocked and announced themselves.
A twenty-minute standoff ensued before Brown was arrested; at headquarters he gave multiple statements after being Miranda-warned.
Warrants to arrest Brown were not executed or reviewed by a detached judge until January 3, 2005; the complaints lacked named factual grounds for Brown’s arrest.
Brown was convicted on multiple counts; the appellate court and Supreme Court considered whether the warrant defect rendered the statements inadmissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Brown’s arrest lawful despite defective warrants?	Brown asserts warrants were invalid; arrest improper in a third party’s residence.	State contends probable cause and public-arrest exception made the arrest lawful.	Arrest lawful; no taint from warrant defects; statements admissible.
Do the post-arrest statements flow from an illegal arrest (attenuation)?	Statements should be suppressed as fruits of an unlawful arrest.	Intervening events and lawful arrest sever the causal link; attenuation applies or is unnecessary.	No taint from a lawful arrest; attenuation not required.
Should New York v. Harris be adopted in this context?	Harris may permit admission despite Payton violation.	Harris not applicable here given no Payton violation.	Court need not decide Harris; inapplicable under facts.
Did Brown’s flight and public standoff affect arrest legality?	Arrest inside a third-party home required warrants.	Flight transformed to public-arrest scenario with probable cause to arrest for armed robbery and resisting arrest.	Public-arrest authority established; warrants not required.
Were Brown's Miranda waivers voluntary?	Questioning was coercive; waivers unreliable.	Trial evidence supports voluntary waiver.	Miranda waivers voluntary; statements admissible.

State v. Basil, 202 N.J. 570 (2010) (probable cause standard for arrest without warrant in public places)
Payton v. New York, 445 U.S. 573 (1980) (necessity of warrants for home entries absent consent or exigent circumstances)
State v. Hutchins, 116 N.J. 457 (1989) (arrest in home requires warrant absent exigent circumstances)
United States v. Watson, 423 U.S. 411 (1976) (felony arrests in public places may be valid without a warrant with probable cause)
Steagald v. United States, 451 U.S. 204 (1981) (need for search warrant to arrest in third-party home unless exigent circumstances)
New York v. Harris, 495 U.S. 14 (1990) (exclusionary rule not automatic for statements obtained after a Payton-violation arrest)
Wong Sun v. United States, 371 U.S. 471 (1963) (attentuation/taint doctrine framework for tainted evidence)
Crews v. United States, 445 U.S. 463 (1980) (beginning premise that tainted evidence must be tied to illegal government activity)
State v. Domicz, 188 N.J. 285 (2006) (no unconstitutional intrusion when police contact suspect at residence entrance)
State v. Henry, 133 N.J. 104 (1993) (arrests without warrants in certain public contexts; probable cause standards)
State v. O'Neal, 190 N.J. 601 (2007) (reasonableness of police conduct in investigations)