Law School Case Brief
People v. Robinson - 97 N.Y.2d 341, 741 N.Y.S.2d 147, 767 N.E.2d 638 (2001)
Where a police officer has probable cause to detain a person temporarily for a traffic violation, that seizure does not violate U.S. Const. amend. IV even though the underlying reason for the stop might have been to investigate some other matter.
In three different cases, with varying results upon defendants' motions to suppress, police officers who had observed suspicious conduct inside automobiles stopped the cars after having observed traffic infractions, and arrests for more serious offenses resulted. In each of the cases, defendant argued that the stop was pretextual and in violation of New York State Constitution, article I, § 12. By arguing that the stops were pretextual, defendants claimed that although probable cause existed warranting a stop of the vehicle for a valid traffic infraction, the officer's primary motivation was to conduct some other investigation.
Was there a violation of article I, § 12 of the New York State Constitution in cases where a police officer, whose primary motivation was to conduct some other investigation, stops a vehicle based on probable cause that the driver has committed a traffic infraction?
The Court held that where a police officer has probable cause to believe that the driver of an automobile has committed a traffic violation, a stop did not violate article I, § 12 of the New York State Constitution. In making that determination of probable cause, neither the primary motivation of the officer nor a determination of what a reasonable traffic officer would have done under the circumstances was relevant.
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