People v. Medina, 61 N.Y.2d 951 (1984)

When a police officer has actual knowledge that a suspect has been arrested on a prior charge, the officer has a duty to inquire whether the suspect was represented by counsel on that prior charge before questioning the suspect.

Summary

Medina was questioned regarding a crime. The questioning officer knew Medina had been arrested eight months prior for sodomy by the same police department and assumed Medina had an attorney for that charge. The New York Court of Appeals held that the officer had a duty to inquire whether Medina was represented by an attorney on the prior sodomy charge before questioning him. The court reversed the Appellate Division’s order, suppressed the statements obtained from Medina, and granted a new trial. The court also held that evidence obtained from a vehicle used by Medina was admissible because the registered owner consented to the search.

Facts

The defendant, Medina, was questioned by a police officer about a crime. The officer knew that Medina had been arrested eight months prior on a sodomy charge by the same police department. The officer also assumed that Medina had an attorney on the prior sodomy charge. During the questioning, Medina made statements that were later used against him.

Procedural History

The trial court admitted Medina’s statements into evidence. The Appellate Division affirmed the trial court’s decision. Medina appealed to the New York Court of Appeals.

Issue(s)

1. Whether a police officer who knows that a defendant has been arrested on a prior charge by the same police department and assumes the defendant had an attorney on that prior charge is under an obligation to inquire whether the defendant was represented by an attorney on the earlier charge before questioning the defendant.
2. Whether evidence obtained from a vehicle used by the defendant should be suppressed when the registered owner of the vehicle consented to the search, even though the police initially mentioned a search warrant (later found invalid) before obtaining consent.

Holding

1. Yes, because when a police officer has actual notice that a defendant was arrested on a prior charge and assumes that the defendant had an attorney, the officer is under an obligation to inquire whether the defendant was represented by an attorney on the earlier charge.
2. No, because an affirmed finding of consent of the registered owner negates the claim that the consent was merely acquiescence to a search warrant.

Court’s Reasoning

The court reasoned that because the officer had actual knowledge of the prior arrest and assumed Medina had an attorney, the officer was obligated to inquire about the representation. The court relied on People v. Bartolomeo, 53 N.Y.2d 225, 232, stating that the officer was “under an obligation to inquire whether defendant was represented by an attorney” on the earlier charge. The court also cited People v. Ramos, 40 N.Y.2d 610, 617-618. This duty to inquire is triggered by the officer’s actual knowledge of the prior representation. If the officer had no such knowledge, the rule would not apply.

Regarding the vehicle search, the court found that the woman with whom Medina was living, who was also the registered owner of the vehicle, consented to the search. The fact that the police mentioned a search warrant (later found invalid) before she consented did not automatically mean she was merely acquiescing to the warrant. The court found that her statement that “it wouldn’t be necessary, that she would cooperate and [the police] could look at the car, to do anything we want to do” indicated valid consent. The court emphasized that there was an “affirmed finding of consent of the registered owner.” This suggests a high level of deference given to the lower court’s factual finding on the consent issue.