People v. Jennings, 54 N.Y.2d 518 (1981)
Police may not block a vehicle, thereby significantly interrupting a person’s liberty of movement and effecting an unconstitutional seizure, based solely on ‘innocuous behavior’ that might at most justify an inquiry.
Summary
This case addresses the level of suspicion required for police to block a vehicle, thus restricting an individual’s freedom of movement. The Court of Appeals held that blocking a vehicle constitutes an unconstitutional seizure when based only on innocuous behavior that might justify further investigation. The court reasoned that the police action was excessively intrusive, exceeding the permissible scope of a brief investigatory stop. Statements obtained as a direct result of the illegal seizure were deemed inadmissible. The decision underscores the importance of balancing law enforcement’s need to investigate potential criminal activity with an individual’s constitutional right to be free from unreasonable searches and seizures.
Facts
Two plainclothes police officers in an unmarked car were conducting routine patrol in the Lake Success Shopping Center. The officers observed a co-defendant, Milton, walking back and forth in front of the stores. Milton met the defendant, Jennings, who exited a restaurant. They drove to an adjacent parking lot. The officers followed them and blocked their vehicle by parking perpendicularly in front of it.
Procedural History
The defendant was indicted, presumably for possession of evidence found after the stop. The trial court denied a motion to suppress statements made by the defendant following the vehicle stop. The Appellate Division affirmed. The New York Court of Appeals reversed the Appellate Division’s order and dismissed the indictment.
Issue(s)
Whether the activities of the defendant, as observed by the police, justified blocking the defendant’s vehicle, preventing its forward movement, thereby effecting a seizure under the Fourth Amendment.
Holding
No, because blocking the vehicle constituted an excessively intrusive seizure, violating the defendant’s constitutional rights, as the observed behavior was innocuous and insufficient to justify such an intrusion.
Court’s Reasoning
The Court of Appeals determined that the police officers’ act of blocking the defendant’s vehicle constituted an unconstitutional seizure. The court reasoned that the defendant’s behavior prior to the stop was “relatively innocuous” and might have justified further inquiry under the standard articulated in People v. De Bour, 40 N.Y.2d 210, which governs police encounters with citizens. However, blocking the vehicle was deemed excessively intrusive because it