People v. Coffey, 12 N.Y.2d 443 (1963)
The identity of an informant need not be disclosed at a suppression hearing if there is sufficient evidence, apart from the informant’s communication, to establish probable cause for a search.
Summary
Coffey was convicted of possessing a hypodermic needle after a search revealed the needle and glassine envelopes. At a suppression hearing, Coffey argued that the police illegally obtained the evidence and requested the identity of the informant who prompted the search. The New York Court of Appeals affirmed the conviction, holding that the informant’s identity need not be disclosed because the detective’s observations, combined with the informant’s tip, provided probable cause for the search. The court balanced the public interest in effective law enforcement with the defendant’s right to a fair trial, concluding nondisclosure was appropriate in this case.
Facts
A New York City detective met with a confidential informant, a drug addict, who told him that Coffey possessed narcotics and was selling them. The informant described Coffey’s appearance and pointed him out to the detective. The detective testified that the informant had previously provided information that led to 15 convictions. The detective then observed an individual known to him as a drug addict holding money and talking to Coffey. As the detective approached, the individual quickly put the money away and walked away. The detective searched Coffey and found a hypodermic needle and 13 glassine envelopes containing a white powder (later determined to not be a narcotic substance).
Procedural History
Coffey moved to suppress the evidence, arguing it was illegally obtained. The Criminal Court denied the motion. Coffey pleaded guilty to violating section 1747-d of the Penal Law. The Appellate Term affirmed the conviction. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the failure to disclose the identity of the informant at the suppression hearing violated the defendant’s right to a fair trial when the detective’s observations, combined with the informant’s tip, provided probable cause for the search.
Holding
No, because there was sufficient evidence, apart from the informant’s communication, to establish probable cause for the search. The State is not bound to reveal the identity of the informant.
Court’s Reasoning
The court relied on its prior decision in People v. Malinsky, stating that disclosure of an informant’s identity is required only in rare cases where there is insufficient evidence, apart from the arresting officer’s testimony about the informer’s communications, to establish probable cause. The court found that this case did not fall into that category. The court acknowledged that the detective’s story about the informant was not, by itself, proof beyond a reasonable doubt. However, the court emphasized that the standard for a search is