People v. Pimentel, 93 N.Y.2d 982 (1999)
A defendant is entitled to a suppression hearing if their motion papers contain factual allegations that, if true, would support the grounds for suppression, especially when the defendant has limited access to information about the basis for their arrest.
Summary
Pimentel was arrested for selling crack cocaine. He moved to suppress evidence, specifically a beeper, arguing the police lacked a legal basis for the arrest and search. He asserted he did not sell or assist in selling drugs. The trial court denied the motion without a hearing. The New York Court of Appeals reversed, holding that Pimentel’s factual allegations, combined with limited information available to him and the People’s conclusory response, were sufficient to warrant a suppression hearing. The case was remitted for a hearing to determine if the evidence should be suppressed.
Facts
The arresting officer allegedly observed Pimentel accept currency from a customer and escort the customer to another individual who provided crack cocaine. Pimentel was arrested. At the time of arrest, a beeper was found on Pimentel. Pimentel asserted that he did not sell drugs or assist others in selling or possessing drugs, and that the police were either mistaken or lying about his role.
Procedural History
Pimentel moved to suppress the beeper. The trial court denied the motion without a hearing, concluding that Pimentel failed to raise a factual issue requiring a hearing. Pimentel was convicted of drug charges. The Appellate Division affirmed the conviction. The New York Court of Appeals reversed and remitted the case for a suppression hearing.
Issue(s)
Whether the defendant’s motion papers contained sufficient factual allegations to warrant a suppression hearing regarding the beeper found on his person at the time of arrest.
Holding
Yes, because Pimentel denied selling drugs or assisting others in selling or possessing drugs, and this denial, considered in the context of the limited information available to him and the People’s uninformative response, was sufficient to raise a factual issue requiring a hearing.
Court’s Reasoning
The Court of Appeals relied on People v. Mendoza, 82 N.Y.2d 415, which established guidelines for determining whether motion papers are sufficient to warrant a suppression hearing. The Court stated that a motion may be summarily denied if “‘the sworn allegations of fact do not as a matter of law support the ground alleged’” to require suppression. The court should consider the face of the pleadings, assessed in conjunction with the context of the motion, and the defendant’s access to information. In this case, Pimentel denied participating in the drug sale. Given the “meager information” available to Pimentel (the complaint alleged he received money and escorted the purchaser), he could do little more than deny participation. The People’s response added no further factual details justifying the arrest. The Court stated that “[b]y failing to set forth the facts leading to defendant’s arrest, the People failed to render defendant’s flat denial insufficient.” The Court emphasized that Pimentel was not obligated to provide an “innocent explanation” for his conduct when the People’s assertions were largely conclusory. Therefore, the Court held that Pimentel’s allegations were sufficient to warrant a hearing, and remitted the case for that purpose.