People v. Reynoso, 59 N.Y.2d 682 (1983)
An appellate court will not review an issue raised for the first time on appeal if it was not properly preserved in the lower court.
Summary
Police officers, acting on overheard incriminating conversations, entered the defendant’s apartment without a warrant. The defendant argued that probable cause was lacking because the officers were not lawfully present in the hallway of the restricted-access building. The New York Court of Appeals affirmed the lower court’s decision, holding that the defendant failed to preserve the argument regarding the legality of the officers’ presence in the building by not raising it during the suppression hearing. Additionally, the court found no reviewable issue of law concerning probable cause and exigent circumstances, given the affirmance of the suppression court’s findings. Thus, the warrantless entry was upheld.
Facts
Federal agents and police officers overheard incriminating conversations emanating from the defendant’s apartment.
Based on these conversations, the officers entered the defendant’s apartment without obtaining a warrant.
The building was a locked, restricted-access, multiple-unit dwelling.
Procedural History
The defendant sought to suppress evidence obtained from the warrantless entry.
The suppression court upheld the warrantless entry.
The Appellate Division affirmed the suppression court’s decision.
The case was appealed to the New York Court of Appeals.
Issue(s)
1. Whether the officers’ entry into the common areas of the locked, restricted access multiple-unit dwelling was lawful, thereby establishing probable cause for the warrantless entry into the defendant’s apartment.
2. Whether the information available to the officers was sufficient to support a finding of probable cause and exigent circumstances for the warrantless entry.
Holding
1. No, because the defendant failed to preserve the issue of the legality of the officers’ presence in the building by not questioning it during the suppression hearing.
2. No, because the affirmance of the suppression court’s findings on probable cause and exigent circumstances leaves no reviewable issue of law.
Court’s Reasoning
The Court of Appeals based its decision on the principle of preservation of issues for appellate review. It emphasized that arguments not raised at the suppression hearing cannot be raised for the first time on appeal. The court stated, “Examination of the record of the suppression hearing reveals, however, that the legality of these officers’ presence in the building was never questioned by defendant and that argument is thus not preserved for review by this court.” The court cited People v. Martin, 50 NY2d 1029 as precedent. Because the defendant did not challenge the officers’ presence in the building during the suppression hearing, the court declined to consider the argument on appeal.
Regarding the sufficiency of the information to support probable cause and exigent circumstances, the court found no reviewable issue of law because the suppression court’s findings on these issues had been affirmed. The court cited People v. Harrison, 57 NY2d 470. The court effectively deferred to the lower courts’ factual findings, as its appellate jurisdiction is generally limited to questions of law.
The court’s decision underscores the importance of raising all relevant arguments at the trial level to preserve them for appellate review. Failure to do so can result in the appellate court declining to address the merits of the argument, as occurred in this case. This rule promotes judicial efficiency and fairness by ensuring that the trial court has the first opportunity to address and resolve the issues presented.