What is the test for denying a motion to suppress statements from a witness in a criminal case?

"New York", United States of America

The following excerpt is from People v. Cyprien, 181 Misc 2d 978, 695 N.Y.S.2d 681 (N.Y. City Ct. 1999):

People v. Satornino, 153 A.D.2d 595, 544 N.Y.S.2d 224 (2nd Dept.1989), most closely resembles the instant matter. The defendant appealed the denial of his motion to suppress his statements, claiming that his warrantless arrest in his home was a Payton violation.. The court held that the defendant's mother, who owned the home, had consented to the detectives' entry, reasoning that "[c]onsent can be

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