Before trial, the defendant sought to suppress his oral and written statements as fruits of an unlawful arrest not supported by probable cause.

The United States District Court found the arrest to be proper and admitted the evidence, and a jury then convicted the defendant of a federal crime.

While the defendant's petition for rehearing was pending before the Court of Appeals, the United States Supreme Court decided Payton v. New York, 445 U.S. 573 (1980), in which it was held that the Fourth Amendment prohibits the police from making a warrantless and nonconsensual entry into a suspect's home to make a routine felony arrest.

The Court of Appeals granted the defendant's petition for rehearing, withdrew its prior opinion, and on the strength of Payton v. New York reversed the judgment of conviction.

The Court of Appeals disagreed, denied the petition for rehearing, and amended its opinion to clarify that Payton did apply retroactively.