People v. Stith, 69 N.Y.2d 313 (1987)
The inevitable discovery exception to the exclusionary rule does not apply when the evidence sought to be admitted is the primary evidence obtained as a direct result of an illegal search.
Summary
Defendants were arrested and charged with criminal possession of a weapon after a traffic stop led to an unlawful search of their truck, revealing a loaded gun. They were later charged with criminal possession of stolen property when a registration check revealed the truck was stolen. The lower courts, while acknowledging the illegal search, invoked the inevitable discovery rule, arguing the gun would have been found during a subsequent inventory search. The New York Court of Appeals reversed the weapon possession conviction, holding that the inevitable discovery exception cannot be used to justify the admission of primary evidence obtained directly from an illegal search, while affirming the stolen property conviction.
Facts
State troopers stopped the defendants’ truck for speeding. The driver, Newton, produced a Connecticut driver’s license but could not find the truck’s registration. A trooper, dissatisfied with Newton’s search, entered the truck and found a brown vinyl bag. Inside the bag, he discovered a revolver. Both defendants were arrested for criminal possession of a weapon. During transport to the police barracks, a radio check revealed that Newton’s license was expired and the truck had been stolen. Consequently, the defendants were also charged with criminal possession of stolen property.
Procedural History
The suppression court and the Appellate Division denied the defendants’ motion to suppress the gun, applying the inevitable discovery rule, despite acknowledging the unlawful search. The New York Court of Appeals granted leave to appeal. The Court of Appeals modified the Appellate Division’s order, reversing the weapon possession conviction and affirming the stolen property conviction.
Issue(s)
Whether the inevitable discovery exception to the exclusionary rule applies to primary evidence (the gun) obtained directly as a result of an illegal search, such that the gun should be admissible at trial.
Holding
No, because applying the inevitable discovery rule to primary evidence obtained during an illegal search would dilute the exclusionary rule and undermine its purpose of deterring police misconduct.
Court’s Reasoning
The Court of Appeals distinguished between primary and secondary evidence. The Court acknowledged that the exclusionary rule bars illegally obtained evidence from trial but recognizes exceptions such as the independent source rule, attenuated connection, and inevitable discovery. The Court emphasized that prior applications of the inevitable discovery rule in New York (e.g., People v. Fitzpatrick, People v. Payton) and in federal cases (e.g., Nix v. Williams) involved secondary evidence – evidence derived from information obtained during the illegal search, not the illegally seized evidence itself. In those cases, the rationale for admitting secondary evidence was that the police should not be in a worse position due to an earlier error if the evidence would have been discovered independently. However, applying the rule to primary evidence, as in this case, would effectively excuse the initial illegal conduct. The court reasoned that allowing admission of the gun would be a “post hoc rationalization of the initial wrong” and “would encourage unlawful searches in the hope that probable cause would be developed after the fact.” The Court explicitly stated it would be an unacceptable dilution of the exclusionary rule. The court emphasized the importance of deterring police misconduct. The court noted that its decision rests on both federal law and the independent state ground of the New York Constitution (Article I, § 12).