58 N.Y.2d 27 (1982)
A search warrant is valid if supported by probable cause established by lawfully obtained information, even if the warrant application also contains unlawfully acquired information, provided the lawfully obtained information, standing alone, is sufficient to establish probable cause.
Summary
Defendant appealed his conviction, arguing that evidence seized from his apartment should have been suppressed because the search warrant was based, in part, on illegally obtained information. The New York Court of Appeals affirmed the conviction, holding that the warrant was valid because it was supported by probable cause based on lawfully obtained information, even though the application included some illegally obtained information. The court reasoned that the legally obtained evidence, independent of the illegally obtained evidence, established a sufficient basis for the warrant’s issuance.
Facts
Police discovered a victim’s body and found keys nearby. Lawfully, they determined the keys belonged to an occupant of a specific apartment and fit the defendant’s mailbox. Before opening the mailbox (an action the defendant contested), detectives had other incriminating evidence linking the occupant to the crime. The police then applied for and received a warrant to search Arnau’s apartment. The search revealed further incriminating evidence that Arnau sought to suppress at trial, claiming the warrant was based on illegally obtained information.
Procedural History
The defendant was convicted. He appealed the conviction, arguing that the evidence seized during the search of his apartment should have been suppressed because the search warrant was based in part on illegally obtained information. The New York Court of Appeals affirmed the lower court’s decision, upholding the conviction.
Issue(s)
Whether a search warrant is invalid and the resulting evidence inadmissible if the warrant application contains some unlawfully acquired information, even when the application also contains lawfully acquired information sufficient to establish probable cause.
Holding
No, because the validity of a warrant based on properly obtained information is not tainted even if the same application contained unlawfully acquired information, provided that the lawfully acquired information is sufficient to provide probable cause for the search.
Court’s Reasoning
The Court of Appeals reasoned that the critical inquiry is whether the warrant was supported by probable cause based on lawfully obtained information. The court cited People v. Arnau, 58 NY2d 27, 38: “The validity of the warrant to search the apartment based upon this properly obtained information, would not be tainted even if the same application contained unlawfully acquired information; provided, of course, that the lawfully acquired information is sufficient to provide probable cause for the search.” Here, the lawfully obtained evidence that the defendant owned keys found near the victim’s body and that these keys fit his mailbox, together with other lawfully obtained incriminating evidence, was sufficient to establish probable cause. The court emphasized that all evidence, including that the keys fit the defendant’s mailbox, was included in the warrant application and, establishing a probability that the killer lived in the apartment, provided ample cause for the issuance of the warrant. The court found any improperly obtained evidence did not invalidate the warrant, given the independent basis for probable cause. The court also considered and rejected the defendant’s other arguments as meritless.