People v. Wilson, 57 N.Y.2d 786 (1982)
Evidence obtained following an illegal detention is admissible if the taint from the initial illegality is sufficiently attenuated by intervening events and investigation, breaking the causal chain between the unlawful conduct and the acquisition of the evidence.
Summary
The New York Court of Appeals addressed whether identifications and statements obtained after an illegal detention should be suppressed as “fruits of the poisonous tree.” The court held that even though the initial detention was unlawful for lacking probable cause, the subsequent lineup identification and statements were admissible because the taint of the illegal detention was attenuated by the intervening time and the continued independent investigation by the Transit Authority police. The police obtained the defendant’s name, address, and photograph during the illegal detention, but this was considered basic identification information. A ten-day interval and further investigation, including informing the defendant of his rights before the lineup, sufficiently purged the taint of the initial illegality.
Facts
Transit Authority police stopped the defendant based on reasonable suspicion, but the suppression court later determined they lacked probable cause for the detention. During the illegal detention, the police obtained the defendant’s name, address, and photograph. Ten days later, the police, as part of their ongoing investigation, asked the defendant to participate in a lineup, informing him of his rights, and he agreed.
Procedural History
The suppression court determined that the initial stop was based on reasonable suspicion, but the subsequent detention lacked probable cause. The defendant sought to suppress the lineup identification and subsequent statements as fruits of the illegal detention. The lower court denied the motion to suppress. The Appellate Division affirmed.
Issue(s)
Whether identifications and statements obtained following an illegal detention must be suppressed as “fruits of the poisonous tree,” even if intervening events and investigation have occurred.
Holding
No, because the exploitation of the illegality was sufficiently attenuated by the intervening time and investigation that suppression of the lineup identification and subsequent statements made by the defendant was not required.
Court’s Reasoning
The court applied the attenuation doctrine, derived from Wong Sun v. United States, to determine whether the connection between the illegal detention and the subsequent evidence was sufficiently weak to permit the use of the evidence at trial. The court reasoned that the police were entitled to make reasonable inquiry as to the person’s identity when acting on reasonable suspicion, and obtaining name, address, and photograph was simply gathering identification information. The court emphasized that the intervening ten-day period and the independent investigation by the Transit Authority police, coupled with informing the defendant of his rights before the lineup, sufficiently attenuated any taint from the initial unlawful detention. The court noted, “the facts of this case clearly indicate that any taint flowing from the initial unlawful detention was attenuated by the intervening investigation.” The photograph obtained during the detention was used in a photo array, but not offered as evidence at trial. This further supported the conclusion that the lineup identification was independent of the initial detention.