People v. Floyd, 26 N.Y.2d 558 (1970)
Evidence obtained as a result of an unlawful arrest, specifically one where police fail to announce their presence and purpose before entering a private residence without exigent circumstances, is inadmissible under the Fourth and Fourteenth Amendments.
Summary
Floyd was convicted of felony and misdemeanor narcotics possession. The conviction stemmed from evidence seized after police, acting on an anonymous tip and verifying a federal forgery warrant, entered his hotel room at 7:00 AM without knocking or announcing themselves. Observing drug paraphernalia in plain view, they arrested and searched Floyd, discovering heroin. The New York Court of Appeals reversed the conviction, holding that the evidence was illegally obtained because the police violated the state’s “knock and announce” rule without justification, and the evidence was therefore inadmissible under the exclusionary rule.
Facts
An anonymous tip alerted New York City police that Floyd was wanted on a federal forgery warrant.
Police verified the warrant and proceeded to Floyd’s hotel.
At 7:00 AM, three officers obtained a passkey from the hotel clerk and entered Floyd’s room without knocking or announcing their presence or purpose.
Upon entering, the police observed narcotics paraphernalia in plain view.
Floyd was arrested and handcuffed, and a subsequent search revealed heroin hidden in a pillowcase.
Procedural History
The trial court denied Floyd’s motion to suppress the seized evidence.
Floyd was convicted of felony and misdemeanor drug possession.
The Appellate Division affirmed the conviction.
The New York Court of Appeals reversed the Appellate Division’s decision.
Issue(s)
Whether evidence seized following a “no-knock” entry by police to execute an arrest warrant is admissible when there are no exigent circumstances justifying the failure to announce their presence and purpose.
Holding
Yes, because the police failed to comply with the “knock and announce” rule without any exigent circumstances excusing their non-compliance, rendering the subsequent search and seizure unlawful, and the evidence inadmissible.
Court’s Reasoning
The Court relied on New York statutes and common law requiring police to announce their presence and purpose before forcibly entering a residence to make an arrest. The Court acknowledged exceptions to this rule in exigent circumstances, such as the imminent destruction of evidence, escape, or increased risk to the police or others. It cited Ker v. California, 374 U.S. 23 (1963) regarding the potential destruction of evidence. However, the Court found no such circumstances present in Floyd’s case. There was no reason to believe Floyd was likely to escape or present a danger to the officers. The court noted, “True, in this case there was matter that was both contraband and evidence, but before entry the police did not have the slightest reason to believe that the matter was present in the premises.” The Court stated the police’s belief that he had previously evaded an officer was irrelevant. Furthermore, the court found that the officers drawing their weapons before entering the room, did not demonstrate that there were exigent circumstances, but that this was extrahazardous given that they were entering by stealth without notice. The Court determined that the arrest was unlawful, citing Miller v. United States, 357 U.S. 301 (1958) and Sabbath v. United States, 391 U.S. 585 (1968). Because the arrest was unlawful, the evidence seized during the subsequent search was inadmissible under the exclusionary rule, which applies to state arrests through the Fourteenth Amendment, as established in Mapp v. Ohio, 367 U.S. 643 (1961) and Ker v. California, 374 U.S. 23 (1963). The court explicitly declined to determine if the search had been permissible under Chimel v. California, 395 U.S. 752 (1969), given that there was already a violation based on the entry of the room.