People v. Mejia, 69 N.Y.2d 853 (1987)

Evidence obtained during a street detention is admissible if the police had reasonable suspicion to justify the detention, and evidence obtained from a search of a residence is admissible if consent to enter was freely given.

Summary

The New York Court of Appeals upheld the defendant’s conviction for robbery, finding that his initial street detention was justified by reasonable suspicion and that he consented to the police entry into his apartment. The court found no error in admitting testimony about a skirt the defendant discarded while fleeing, as it was relevant to identification.

Facts

In the early morning hours, police officers investigating another crime in an area of apartment buildings observed the defendant running. They noticed two other men nearby and suspected the defendant might be the victim of a crime. The police called to the defendant, who stopped, looked at them, and then ran away, discarding a black skirt as he fled. The police pursued and questioned him, and he gave his name and address, which they verified. Later, the police entered the defendant’s apartment, where they arrested him and seized a blue jacket.

Procedural History

The defendant was convicted of robbery in the first degree and sentenced as a persistent violent felony offender. He appealed, challenging the admission of statements made during the street detention, the observation of a fresh cut on his hand during the stop, and the seizure of a blue jacket from his apartment. The hearing court found the street detention justified and the apartment entry consensual. The Appellate Division upheld these findings.

Issue(s)

1. Whether the defendant’s statements, the police observations, and the discarded skirt should have been suppressed as products of an unlawful street detention.
2. Whether the blue jacket should have been suppressed as the fruit of an unlawful warrantless arrest in his apartment.
3. Whether testimony about the black skirt was improperly admitted.

Holding

1. No, because the police had an articulable reason for the initial attempt to talk with the defendant and reasonable suspicion to justify their detention while they questioned him.
2. No, because the entry into the defendant’s apartment was made with his consent, rendering the subsequent warrantless arrest lawful, and the jacket was properly seized incident to that arrest.
3. No, because the testimony concerning the skirt was relevant to the issue of identification.

Court’s Reasoning

The court reasoned that the police had an articulable reason to attempt to speak with the defendant and reasonable suspicion to detain him based on his running away after being called to, and discarding the skirt. Citing People v. Leung, 68 NY2d 734 and People v. Howard, 50 NY2d 583, the court emphasized the permissibility of brief detentions based on reasonable suspicion. The court also deferred to the lower courts’ finding of consent to enter the apartment, stating, “These determinations involved mixed questions of law and fact, and because there is evidence in the record to support the hearing court’s findings, undisturbed by the Appellate Division, our review process is at an end (see, People v Harrison, 57 NY2d 470, 477).” The court found the testimony about the skirt relevant for identification, as it linked the defendant to the crime through his possession of a similar item at a closely related time, noting the victim’s testimony that her attacker was carrying something black. The skirt itself was not admitted. The court emphasized that the evidence “helped to link him to the crime.”