People v. Woods, 98 N.Y.2d 627 (2002)
A defendant’s flight in response to an approach by the police, combined with other specific circumstances indicating that the suspect may be engaged in criminal activity, may give rise to reasonable suspicion, the necessary predicate for police pursuit.
Summary
This case addresses whether police had reasonable suspicion to pursue a suspect who fled upon their approach. Police responded to a report of a gunpoint robbery involving three African-American men, where the victim was described as an African-American man in all white. Arriving at the scene, they found the defendant, matching the description of the victim, but he fled when approached. During the pursuit, the defendant discarded a jacket containing a gun and marijuana. The New York Court of Appeals held that the temporal proximity between the robbery report and the encounter, the matching description, and the defendant’s flight, provided reasonable suspicion for the police pursuit, justifying the denial of the motion to suppress the evidence.
Facts
On July 2, 1997, two police officers received radio reports of a gunpoint robbery by three African-American men. The victim was described as an African-American man in all white clothing, waiting for assistance at Mott and Central Avenues in Queens. Within a minute, the officers arrived and observed the defendant, an African-American male dressed in white and carrying a white jacket, at the specified location. When an officer approached to offer assistance, the defendant fled. During the chase, the defendant threw his jacket to the ground before being apprehended. The jacket contained a loaded .32 caliber revolver and 20 bags of marijuana.
Procedural History
The defendant was charged with criminal possession of a weapon and marijuana. He moved to suppress the gun and marijuana, but the motion was denied. A jury convicted him on both counts. The Appellate Division affirmed the conviction, with one Justice dissenting.
Issue(s)
Whether the defendant’s flight in response to a police approach, coupled with other specific circumstances, constituted reasonable suspicion justifying police pursuit.
Holding
Yes, because the temporal proximity of the robbery report, the matching description of the defendant, and his flight were sufficient to create reasonable suspicion for the police pursuit.
Court’s Reasoning
The Court of Appeals relied on precedent establishing that flight combined with other specific circumstances can create reasonable suspicion. Reasonable suspicion is defined as “that ‘quantum of knowledge sufficient to induce an ordinarily prudent and cautious [person] under the circumstances to believe criminal activity is at hand’ ” (quoting People v. Martinez, 80 N.Y.2d 444, 448 (1992)). The court emphasized that the determination of reasonable suspicion involves mixed questions of law and fact, and appellate courts are bound by the lower courts’ findings if there is evidence in the record to support them. Here, the court found that the temporal proximity between the robbery report and the officers’ arrival, the defendant matching the victim’s description, and the defendant’s flight (an action inconsistent with being a robbery victim) provided sufficient evidence to support the lower courts’ determination of reasonable suspicion. The court stated that the issue was beyond further review because sufficient evidence supported the lower court’s finding. The Court explicitly referenced and applied the principles articulated in People v. Sierra, 83 N.Y.2d 928 (1994) and People v. Holmes, 81 N.Y.2d 1056 (1993).