People v. Camarre, 18 N.Y.3d 905 (2012)
Suppression of evidence is not warranted for violations of statutory requirements unless those requirements are designed to protect constitutional rights; clerical errors in a search warrant that do not implicate constitutional rights do not justify suppression.
Summary
In People v. Camarre, the New York Court of Appeals addressed whether a clerical error on a search warrant—specifically, the failure to properly name the issuing court—justified the suppression of evidence seized during the warrant’s execution. The Court held that suppression was not warranted because the statutory requirement to name the issuing court (CPL 690.45[1]) was not designed to protect a constitutional right. The dissent argued that the majority’s decision was an unwarranted expansion of the exclusionary rule to a non-constitutional violation.
Facts
A search warrant was issued, but the warrant contained a clerical error failing to properly name the issuing court. The warrant otherwise complied with requirements for describing the place to be searched and the items to be seized. The defendant sought to suppress the evidence seized during the execution of the warrant, arguing that the error violated CPL 690.45(1).
Procedural History
The County Court denied the motion to suppress. The Appellate Division reversed, granting the motion to suppress, holding that the warrant was defective. The People appealed to the New York Court of Appeals.
Issue(s)
Whether the failure to properly name the issuing court on a search warrant, in violation of CPL 690.45(1), requires suppression of the evidence seized pursuant to the warrant.
Holding
No, because the statutory requirement to name the issuing court is not designed to protect a constitutional right, and the warrant otherwise complied with constitutional requirements for valid search warrants.
Court’s Reasoning
The Court of Appeals relied on established precedent, including People v. Taylor, People v. Patterson, and People v. Greene, which held that suppression is only warranted when a statutory violation implicates a constitutionally protected right. The Court distinguished the case from Taylor, where the statutory violation (failure to record testimony supporting a search warrant) implicated the constitutional requirement of probable cause. The Court reasoned that CPL 690.45(1)’s requirement to name the issuing court is a formal requirement that does not, in itself, protect a constitutional right.
The Court stated that a violation of a statute does not, without more, justify suppressing the evidence to which that violation leads and they have made an exception to this rule only when the principal purpose of a statute is to protect a constitutional right. The court reasoned that the warrant did comply with those parts of CPL 690.45 that are designed for the protection of constitutional rights. Specifically, the warrant complied with CPL 690.45 (4) and (5) by describing the place to be searched and the things to be seized. These subdivisions implement the requirements of the Fourth Amendment to the United States Constitution and article I, § 12 of the New York Constitution.
Judge Smith dissented, arguing that the majority was improperly expanding the exclusionary rule to a non-constitutional violation. The dissent emphasized that suppression is a drastic remedy that should only be used to protect constitutional rights, not to punish every statutory violation. Quoting People v. Defore, the dissent noted that suppression often means “[t]he criminal is to go free because the constable has blundered.”