What's a Payton violation (law Q)

In last night’s episode of Law and Order SVU, the police came to a lady’s home to arrest her daughter, and just as they were taking her to the door, the mother confessed to the crime. The mother was arrested and taken down to the station, where she gave a more detailed confession. The confession was thrown out due to a Payton violation. What is this, and is it part of NYS law or Federal law?

The decision in Payton v. New York said that the 4th amendment doesn’t allow the police to to make a warrentless and nonconsentual entry into a home to make an arrest. Also check out New York v. Harris.

Thanks Captain Amazing.