The People v. Sean Garvin
N0. 82
| NY | Oct 24, 2017Background
- Defendant Sean Garvin was arrested without a warrant after police, having developed probable cause from fingerprint matches, went to his two‑family house, knocked, and he opened his apartment door; officers handcuffed him while he stood in the doorway and transported him to the precinct.
- At suppression, Garvin argued the warrantless doorway arrest violated Payton v. New York and that police could have obtained a warrant; he also argued subsequent statements should be suppressed under People v. Harris because the tactic circumvented New York's right‑to‑counsel protections.
- Supreme Court denied suppression; a bench trial convicted Garvin of multiple robberies and he was adjudicated a persistent felony offender and sentenced to 15 years to life. The Appellate Division affirmed, finding Garvin voluntarily emerged and was arrested at the threshold.
- The Court of Appeals, by a majority (Stein, J.), reaffirmed prior New York precedent allowing warrantless arrests of occupants who voluntarily come to the door or stand in the threshold in response to police knock, and declined to adopt the Second Circuit’s Allen rule that an arrest while the occupant remains inside the home violates Payton.
- The majority rejected overturning stare decisis and declined to recognize a new Payton violation based on subjective police intent or on New York‑specific expansion of Payton/Harris; several justices dissented, urging greater protection under the State Constitution or different treatment of preplanned at‑home arrests.
Issues
| Issue | People’s Argument | Garvin’s Argument | Held |
|---|---|---|---|
| Whether a warrantless arrest at the doorway violates Payton | Warrantless threshold arrests are permissible when occupant voluntarily emerges; no Payton violation absent police crossing the threshold | Arrest while standing in doorway summoned by police violated Payton; police could have secured a warrant | Affirmed: No Payton violation where occupant voluntarily answered and was arrested in doorway; courts follow precedent allowing such arrests |
| Whether subjective police intent to arrest at home creates a Payton violation | Intent irrelevant; Fourth Amendment asks for objective reasonableness, not officers’ subjective plans | Police intent to effect a preplanned warrantless at‑home arrest should render seizure unlawful | Rejected: Court refuses to base rule on subjective intent; adopts objective standard and rejects expanding Payton on that basis |
| Whether Garvin’s post‑arrest statements must be suppressed under Harris (New York’s broader right‑to‑counsel rule) | Because no Payton violation, Harris attenuation rule inapplicable; statements admissible | Preplanned at‑home arrest circumvented New York right to counsel; statements should be suppressed | Held: No suppression — majority declines to extend Harris here because it would require overruling earlier precedent; several dissenters would suppress or remand |
| Validity of persistent felony offender adjudication under Apprendi | Prior convictions determine eligibility for enhanced sentence; scheme constitutional under state precedent | Statutory requirement that court find defendant’s history/circumstances makes enhancement a judicial fact in tension with Apprendi | Majority: Adheres to precedent (Prindle et al.) and affirms; one Justice dissents arguing scheme violates Apprendi |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (1980) (warrantless, nonconsensual entry into home to effect routine felony arrest prohibited absent exigent circumstances)
- Kentucky v. King, 563 U.S. 452 (2011) (knock‑and‑talk by officers without warrant is lawful; courts assess reasonableness objectively and reject inquiries into subjective intent)
- People v. Harris, 77 N.Y.2d 434 (1991) (New York’s rule requiring suppression of statements following a Payton violation unless taint is attenuated; emphasizes State right to counsel)
- People v. McBride, 14 N.Y.3d 440 (2010) (recognizes police may go to a suspect’s residence and request voluntary exit even if they could have obtained a warrant)
- United States v. Allen, 813 F.3d 76 (2d Cir. 2016) (Second Circuit: summoning a suspect to the door and arresting while he remains inside violates Payton; represents a different federal approach)
- People v. Minley, 68 N.Y.2d 952 (1986) (threshold/doorway arrest precedent; court upheld warrantless arrest where defendant voluntarily appeared at door)
- People v. Reynoso, 2 N.Y.3d 820 (2004) (upheld planned, warrantless doorway arrest where defendant voluntarily exited or responded to police request)
- People v. Spencer, 29 N.Y.3d 302 (2017) (reaffirmed prior line allowing voluntary threshold arrests; emphasizes objective Fourth Amendment reasonableness)
- People v. Prindle, 29 N.Y.3d 463 (2017) (controls review of persistent felony offender adjudication and was followed on sentencing challenge)