People v. Adams, 32 N.Y.2d 451 (1973)
A full search of a person incident to arrest for a Vehicle and Traffic Law violation is not justified without reasonable grounds to believe the search will produce evidence related to the crime or is necessary for officer safety.
Summary
The New York Court of Appeals held that a full search of a defendant’s person incident to an arrest for driving a vehicle with an altered identification number (a violation of the Vehicle and Traffic Law) was unlawful because the officer lacked reasonable grounds to believe the search would reveal evidence related to the crime or that the defendant posed a threat. The court emphasized that the search must be justified by the nature of the offense and surrounding circumstances, and that the prosecution conceded the officer lacked probable cause independent of the traffic violation. The evidence seized (marijuana) was suppressed.
Facts
A police officer stopped the defendant for driving with high beam headlights. Upon checking the vehicle’s registration, the officer discovered the vehicle identification number did not match the number in the National Auto Check Book for that vehicle type. The officer arrested the defendant for having an altered identification number in violation of Vehicle and Traffic Law § 422. The officer then conducted a full search of the defendant’s person, which revealed marijuana in his coat pocket. Subsequently, a search of the car revealed more marijuana, a scale, and manila envelopes.
Procedural History
The defendant was charged with possession of marijuana and possession of a motor vehicle with an altered identification number. The defendant moved to suppress the evidence seized during the searches. The Criminal Court of the City of New York granted the motion to suppress. The Appellate Term reversed, upholding the search as incident to a lawful arrest. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether a full search of a person is permissible incident to an arrest for a violation of Vehicle and Traffic Law § 422 (possession of a motor vehicle with an altered identification number) without any additional justification.
Holding
No, because the search was not justified by the need to seize evidence related to the crime or to ensure the officer’s safety, and the prosecution conceded the officer lacked probable cause independent of the traffic violation.
Court’s Reasoning
The Court of Appeals emphasized that the Fourth Amendment requires searches to be reasonable. It noted that reasonableness is determined by examining the nature of the offense and the surrounding circumstances. The court distinguished this case from situations involving frisks for weapons or searches based on probable cause for a more serious crime. The court explicitly stated that “General or exploratory searches are condemned even when they are incident to a lawful arrest.” The court reasoned that after the defendant produced his license and registration, and without any indication he could not explain the discrepancy in the identification number, there was no justifiable belief that a search of his person was warranted. The court emphasized that the legitimate objectives of a search incident to arrest are: “(1) seizure of fruits, instrumentalities and other evidence of the crime for which the arrest is made in order to prevent its destruction or concealment; and (2) removal of any weapons that the arrestee might seek to use to resist arrest or affect his escape.” Neither of these objectives were present in this case. Judge Jasen dissented, arguing that operating a vehicle with an illegally changed serial number is a misdemeanor indicative of a more serious offense (potentially stolen vehicle), thus justifying the search for evidence of prior ownership. The dissent also highlighted officer safety as a justification for the search.