People v. Bethea

In People v. Bethea, 67 N.Y.2d 364, 368, 493 N.E.2d 937, 502 N.Y.S.2d 713 [1986], after learning about an attempted burglary by two men whose appearance matched that of defendant and his companion, the police stopped them on the street in the vicinity of the crime and questioned them about the contents of a bag they were carrying. Upon discovering that the bag contained a revolver, the police arrested defendant. While transporting him to the police station, one of the officers asked defendant where he had obtained the gun, eliciting an incriminating response. At the precinct, the same officer gave defendant Miranda warnings, and then resumed the interrogation, at which point defendant repeated what he had said in the vehicle. The Court concluded that the Mirandized statement should have been suppressed because it was elicited as part of a single continuous chain of events flowing from the improper, unwarned custodial interrogation in the police car. In Bethea the defendant was arrested, placed in the police vehicle and interrogated while being transported to the police station--the initial incriminating statements were clearly obtained in violation of Miranda requirements. In Bethea, the Mirandized statement was elicited by the same police officer who had accosted defendant on the street, arrested him, and obtained the unwarned statement. Therefore, a reasonable suspect in defendant's position would not have perceived a distinction between the interrogation in the car and the interrogation at the station. Moreover, the defendant had not previously expressed a desire to talk to the police.