People v. Santiago, 13 N.Y.2d 326 (1963)
A warrantless search is lawful if incident to a lawful arrest, and an arrest is lawful if officers have reasonable cause to believe a felony has been committed and the defendant committed it; this reasonable cause can be based on a reliable informant’s tip, especially when corroborated by other factors.
Summary
These consolidated appeals address the legality of searches without warrants in two separate narcotics cases. In People v. Santiago, the court upheld the conviction, finding the search was justified by reliable information from a known drug addict corroborated by police investigation. In People v. Martin, the court reversed the conviction, deeming the search illegal because it was based on unverified information from an unreliable informant and involved an unlawful intrusion into a building. The differing factual scenarios highlight the importance of corroboration and the manner of entry in determining the legality of a warrantless search.
Facts
People v. Santiago: Police officers, acting on information from Elfman, a known drug addict seeking leniency, identified Lee Santiago as her narcotics supplier. Elfman provided Santiago’s address, phone number, and car description. After confirming the phone number and overhearing Elfman arrange a drug purchase with someone she called “Lee,” officers followed Elfman to Santiago’s apartment. Elfman signaled to the officers that narcotics were present, and the officers entered the apartment where they observed Santiago discard glassine envelopes containing heroin. Santiago admitted the drugs belonged to her.
People v. Martin: Police officers, after arresting Robert Void on unrelated charges, received information from him about narcotics being cut up at an apartment on Edgecomb Avenue. Void described the occupant as a woman named Rose and advised that entry should not be made from the front. Without verifying Void’s information, officers entered the building by forcing open a skylight. They saw narcotics in an apartment through an open door. Rosalee Martin was later arrested in another apartment and charged with possession of the drugs found in the Edgecomb Avenue apartment.
Procedural History
People v. Santiago: Santiago was convicted of felonious possession of narcotics in the Supreme Court, New York County. The Appellate Division, First Department, affirmed the conviction. The case was appealed to the New York Court of Appeals.
People v. Martin: Martin was convicted of felonious possession of a narcotic drug with intent to sell in the Supreme Court. The Appellate Division, First Department, affirmed the conviction. The case was appealed to the New York Court of Appeals.
Issue(s)
1. People v. Santiago: Whether the warrantless search of Santiago’s apartment was justified by reasonable cause based on information from an informant.
2. People v. Martin: Whether the search of the Edgecomb Avenue apartment was legal, considering the unverified information from the informant and the manner of entry.
Holding
1. People v. Santiago: Yes, because the officers had reasonable cause to believe Santiago was committing a felony based on the informant’s information, which was corroborated by their own investigation.
2. People v. Martin: No, because the informant’s story was not checked against any previous experience with him or against any objective facts, and the evidence was obtained by an illegal and forceful intrusion into the building.
Court’s Reasoning
People v. Santiago: The Court of Appeals emphasized that the legality of the search hinged on whether the officers had reasonable cause to believe that Santiago possessed narcotics with intent to sell. The court found that reasonable cause existed because the officers knew Elfman as a narcotics user and seller, knew of Santiago’s reputation as a seller, verified the phone number Elfman provided, and overheard a phone conversation arranging a drug purchase. The court cited People v. Coffey, stating that “Substantiation of information can come either from the informer’s own character and reputation or from the separate, objective checking of the tale he tells.” The court distinguished this case from situations where an informer’s story is the sole basis for reasonable belief, emphasizing the corroborating evidence in this case.
People v. Martin: The Court of Appeals found the search illegal for two primary reasons. First, the information provided by Void, the informant, was not adequately checked or corroborated. The officers had no prior experience with Void and did not verify his claims before acting on them. Second, the officers gained access to the apartment building through an illegal, forceful intrusion by breaking open a skylight. The court emphasized that such an intrusion into a residential building without a warrant or exigent circumstances is unlawful, citing Johnson v. United States and other cases. The court stated that acting on untested information from a person whose reliability was not otherwise confirmed, combined with the illegal entry, rendered the search unconstitutional.