People v. Anderson, 33 N.Y.2d 172 (1973)
A police officer may conduct a stop and frisk based on reasonable suspicion when an eyewitness provides a specific description of a suspect and the crime, even if the eyewitness’s identity is not fully verified.
Summary
The New York Court of Appeals held that a police officer had reasonable suspicion to stop and frisk a suspect based on an eyewitness report of an attempted robbery. The eyewitness provided a description of the suspect and the crime, and identified the suspect to the officer shortly after the event. The court reasoned that the totality of the circumstances, including the eyewitness’s report, the suspect’s proximity to the crime scene, and the suspect’s behavior when approached, justified the officer’s actions. The court emphasized that while an unsubstantiated report of mere firearm possession is insufficient, a report of firearm use in a crime provides stronger justification.
Facts
At 8:00 PM, an unidentified teenager approached Patrolman Anderson in New York City, reporting he witnessed an attempted robbery. The teenager described the robber as tall, wearing a black leather jacket, bearded, and with a slight afro. Shortly after, the teenager pointed out the defendant, who matched the description and was in the vicinity, as the perpetrator. The teenager confirmed his identification to the officer.
Procedural History
The defendant was charged with a crime related to the gun found during the frisk. He moved to suppress the gun as evidence, arguing the stop and frisk were illegal. The trial court denied the motion. The Appellate Division affirmed the trial court’s decision, upholding the legality of the stop and frisk. The case then went to the New York Court of Appeals.
Issue(s)
Whether, based on an eyewitness report of an attempted robbery and the suspect’s subsequent identification, a police officer had reasonable suspicion to stop and frisk the suspect, even without further verification of the eyewitness’s identity or corroboration of the information provided.
Holding
Yes, because the totality of the circumstances, including the eyewitness’s detailed description of the suspect and the crime, the proximity of the suspect to the crime scene shortly after the event, and the suspect’s actions upon being approached by the officer, provided reasonable suspicion to justify the stop and frisk.
Court’s Reasoning
The court reasoned that the officer had reasonable suspicion to believe a frisk was appropriate based on the eyewitness’s report of an attempted robbery at gunpoint, coupled with the specific identification of the defendant shortly thereafter. The court distinguished this situation from a mere report of firearm possession, stating, “There is a difference of significant degree between a report only that a person has a gun in his possession and another report that a person not only has a gun but that he has just used it for the commission of crime.”
The court acknowledged the importance of protecting citizens from unwarranted police intrusion based on unsubstantiated reports, stating, “A citizen walking our streets should not, without more, be exposed to physical assault by a police officer on the basis of an unsubstantiated report of the mere possession of firearms volunteered by a stranger. To condone such conduct would be to expose innocent persons to harassment by pranksters and irresponsible meddlers.” However, the court found that the specific facts of this case, including the report of a crime involving a firearm and the eyewitness’s identification, provided sufficient justification for the officer’s actions.
The court also considered the defendant’s behavior, noting that he “sort of turned and looked in [the officer’s] direction and started walking away” as the officer approached. While this action alone may not have been sufficient to establish reasonable suspicion, it contributed to the totality of the circumstances that justified the stop and frisk.
The court emphasized that the determination of reasonable suspicion is highly fact-dependent, stating, “The proper determination in cases of this sort must necessarily turn on the facts in each individual case.” The court also cautioned that this case approached the limit for a finding of reasonable suspicion.