People v. Clements, 37 N.Y.2d 675 (1975)
A warrantless search is permissible when exigent circumstances exist, such as the imminent destruction of contraband, and the police have specific, reliable information about the location of the contraband.
Summary
Police arrested Clements and Metzger in their apartment based on information from a reliable informant who had just purchased marijuana there. After the arrests, the police searched a dresser and found additional marijuana. The New York Court of Appeals held that the warrantless search of the dresser was justified due to exigent circumstances (the risk of the drugs being destroyed) coupled with the detailed information provided by the informant. The court emphasized that the search was narrowly focused and not a general exploratory search.
Facts
A named informant told police he knew where large quantities of marijuana could be purchased. The informant agreed to buy marijuana for the police, who searched him and provided him with marked money. The informant went to Clements and Metzger’s apartment and returned with marijuana cigarettes, stating he became nervous due to questioning by the sellers and left when they left the room. Police went to the apartment and arrested Clements. Marijuana and drug paraphernalia were in plain view. Metzger was arrested in the bathroom. Police then searched a dresser described by the informant and found 16 bricks of marijuana in the bottom drawer.
Procedural History
Clements and Metzger moved to suppress the evidence found in the dresser, but the motions were denied by the trial court. They then pleaded guilty. The Appellate Division reversed, granting the motions to suppress as to the marijuana found in the dresser drawers. The People appealed to the New York Court of Appeals.
Issue(s)
Whether the warrantless seizure of marijuana from a closed dresser drawer in an apartment was illegal, where police had legally entered the apartment and had precise, reliable information about the marijuana’s location.
Holding
No, because the seizure was lawful under an exigency exception to the warrant requirement. The police had probable cause and faced exigent circumstances that justified an immediate search to prevent the destruction or removal of the evidence.
Court’s Reasoning
The Court reasoned that the warrantless search was justified by two key factors: exigent circumstances and a specifically focused search based on reliable information. The exigent circumstances included the readily disposable nature of narcotics and the informant’s belief that the sellers were suspicious. The police had specific information from a credible informant about the location and contents of the dresser drawer. The Court distinguished this case from Chimel v. California, noting that this was not a wide-ranging exploratory search. The Court stated, “Crucial then to the legality of the warrantless seizure here is the coexistence of two factors, each significant for itself and more significant in combination. The first is the existence of what are referred to as exigent or exceptional circumstances… The second is the fact that this seizure was specifically focused on a predetermined target, the predetermination of which was based on explicit information furnished by a known and still available individual whose reliability the police had currently substantiated… Most significant the seizure was conducted to prevent the threatened disappearance of tangible evidence.” The Court considered potential alternative actions the police could have taken, such as maintaining surveillance while obtaining a warrant, but concluded that those alternatives would have been more intrusive. The Court found the police acted reasonably given the need for immediate action and the specific knowledge they possessed. The court distinguished from cases where the initial intrusion was unlawful, noting that here, the entry into the apartment was lawful based on probable cause for the arrests. The court remitted to the Appellate Division for review of the facts.