People v. Langen, 60 N.Y.2d 170 (1983)

When police have probable cause to believe that an automobile contains contraband related to the crime for which the driver or passenger is arrested, they may search any container within the vehicle, locked or unlocked, within a reasonable time after the arrest.

Summary

Police stopped Langen after observing suspicious behavior suggesting drug use. A vial of white powder was visible in Langen’s vest pocket upon exiting the vehicle, leading to his arrest. A locked suitcase in the truck’s passenger compartment was then forcibly opened, revealing cash and cocaine. Langen sought to suppress this evidence, arguing the warrantless search of the locked suitcase was unconstitutional. The New York Court of Appeals reversed the lower court’s suppression order, holding that the automobile exception to the warrant requirement permits a search of any container within a vehicle when there is probable cause to believe the vehicle contains contraband related to the crime for which the arrest was made. The Court found that the initial observations coupled with the vial in plain view established probable cause for both the arrest and the vehicle search.

Facts

1. Police observed Langen driving a pickup truck with a female passenger.
2. The passenger was seen holding a rolled bill inserted into a small manila envelope under Langen’s nose.
3. Langen exited the vehicle, revealing a plastic vial containing white powder in his vest pocket.
4. Langen was arrested and given Miranda warnings, after which he disclaimed ownership of a locked traveling bag behind the truck seat.
5. Police forcibly opened the locked bag and discovered cash, a bank book in Langen’s name, and envelopes containing cocaine.

Procedural History

1. Langen moved to suppress the evidence seized from the suitcase.
2. The trial court granted the motion, citing *United States v. Chadwick* and *Arkansas v. Sanders*, reasoning that a warrant was required to search the locked bag.
3. The Appellate Division affirmed without opinion.
4. The New York Court of Appeals granted leave to appeal.

Issue(s)

1. Whether the automobile exception to the warrant requirement allows police to search a locked container within a vehicle’s passenger compartment when there is probable cause to believe the vehicle contains contraband related to the crime for which an occupant was arrested.
2. Whether *United States v. Ross* should be applied retroactively to cases on direct appeal.

Holding

1. Yes, because when the circumstances give rise to probable cause to arrest a driver or passenger in the automobile also support the belief that the automobile contains contraband related to the crime for which the arrest is made, police may search any container, locked or otherwise, located in the automobile.
2. Yes, because under the principles of *United States v. Johnson*, the rule in *Ross* should be applied to all cases on direct review.

Court’s Reasoning

The Court of Appeals relied heavily on the Supreme Court’s decision in *United States v. Ross*, which expanded the scope of the automobile exception. The Court distinguished *Chadwick* and *Sanders*, explaining that those cases involved probable cause focused specifically on the container itself, not a generalized belief that contraband was located somewhere within the vehicle. In *Ross*, the Supreme Court held that a warrantless search of an automobile, based on probable cause, could extend to any part of the vehicle, including containers, that might contain the object of the search. The Court reasoned that “[t]he scope of a warrantless search of an automobile * * * is not defined by the nature of the container in which the contraband is secreted. Rather, it is defined by the object of the search and the places in which [upon *post hoc* determination] there [was] probable cause to believe that it may be found”.

The Court also addressed the issue of retroactivity, applying the framework set forth in *United States v. Johnson*. It found that *Ross* did not represent a “clear break with the past” and thus should be applied retroactively to cases on direct appeal. The Court determined that the police had probable cause to believe the truck contained contraband, justifying the search of the entire vehicle, including the locked suitcase. Furthermore, the Court noted that “given the state of affairs in New York City in 1981, the average moderately aware, reasonable and prudent citizen who saw defendant’s behavior would have drawn the same conclusion as the police officers” regarding the drug activity.

Under the New York State Constitution, the court recognized a “narrow” automobile exception similar to the federal standard. The court stated that the warrantless search was permissible because “upon defendant’s arrest for drug possession, the police had probable cause to believe that contraband related to that crime was located somewhere in the truck. Therefore, they could properly search the entire truck, including any closed containers found therein.” The court emphasized that the probable cause related to the automobile and did not focus exclusively on the container.