People v. Spivey, 46 N.Y.2d 1014 (1979)
Police officers are justified in stopping and frisking a suspect when they have a reasonable suspicion, based on articulable facts, that the suspect has committed, is committing, or is about to commit a crime, and that the suspect is armed and dangerous.
Summary
The New York Court of Appeals addressed the legality of a stop and frisk conducted by police officers who had received a radio call about an armed robbery. The Court held that the officers’ actions were justified because the defendant matched the description of the robber, was in the vicinity of the crime, and acted suspiciously during questioning by refusing to provide his name and address and fidgeting with his hands. This case illustrates the application of the reasonable suspicion standard in the context of a rapidly unfolding investigation of a violent crime.
Facts
Police officers received a radio call informing them of an armed robbery. The defendant was walking on a deserted street in the vicinity of the crime and matched the description of the robber provided in the radio call. When questioned, the defendant refused to furnish his name or a specific address. The defendant repeatedly removed his hands from the radio car and shuffled them around. The officers observed suspicious bulges in the defendant’s jacket pockets.
Procedural History
The lower court ruled that the stop and frisk was unlawful, suppressing the evidence obtained. The prosecution appealed to the New York Court of Appeals.
Issue(s)
Whether police officers, having received a radio call informing them of an armed robbery, were justified in stopping and frisking the defendant, who matched the description of the robber, was walking on a deserted street in the vicinity of the crime, and acted suspiciously during questioning?
Holding
Yes, because based on the totality of the circumstances, the officers had a reasonable suspicion that the defendant had committed an armed robbery and was armed and dangerous.
Court’s Reasoning
The Court reasoned that the police conduct was reasonable given the information available to the officers at the time of the stop and frisk. The Court relied on the following factors: the radio call informing them of an armed robbery, the defendant matching the description of the robber, the defendant’s presence in the vicinity of the crime, and the defendant’s suspicious behavior during questioning. Citing People v. Havelka, 45 NY2d 636, 640-641, the Court stated the officers were justified in stopping the defendant. The Court also found the limited pat-down was justified, explaining “Given this situation and defendant’s status as an armed-robbery suspect, it was quite reasonable for the officer to investigate the suspicious bulges in the jacket pockets.” This decision emphasizes the importance of considering the totality of the circumstances when evaluating the reasonableness of a stop and frisk. The ruling also highlights the diminished expectation of privacy in situations involving violent crimes and potential danger to the public. The Court did not elaborate on dissenting or concurring opinions.