State v. FelixAnnotate this Case
Defendant Devin Felix was convicted of second-degree intentional homicide. The court of appeals reversed, holding that statements and physical evidence obtained from Defendant outside of the home after Miranda warnings were given and waived following a warrantless in-home arrest made in violation of Payton v. New York were not sufficiently attenuated from the unlawful arrest as to be lawful. At issue before the Supreme Court was which analysis governed the admissibility of such evidence, Brown v. Illinois or New York v. Harris, both decisions by the U.S. Supreme Court. The Wisconsin Supreme Court reversed the decision of the court of appeals after adopting the Harris exception to the exclusionary rule for certain evidence obtained after a Payton violation, holding that, where police had probable cause to arrest before the unlawful entry, a warrantless arrest from Defendant's home in violation of Payton required neither the suppression of statements outside of the home after Miranda rights were given and waived nor the suppression of physical evidence obtained from Defendant outside of the home.