In New York v. Harris, 495 U.S. 14 (1990), the Supreme Court considered whether an inculpatory statement was the product of an illegal arrest. The Court held the police had probable cause to arrest Harris, but their entry into his home without a warrant was illegal. Id. at 17. The question was whether a statement given at the police station after Miranda warnings should have been suppressed. Id. at 16. The Court answered that question in the negative, explaining that, because the police had probable cause to arrest him, he was not in unlawful custody when he was taken to the police station. Id. at 18. Noting the attenuation approach in Brown v. Illinois, the Court explained that "attenuation analysis is only appropriate where, as a threshold matter, courts determine that 'the challenged evidence is in some sense the product of illegal government activity.'" Id. at 19 (quoting United States v. Crews, 445 U.S. 463 (1980)).