People v. Martinez, 82 N.Y.2d 436 (1993)
When reviewing a suppression motion denial, the Court of Appeals determines only whether there was record support for the finding that police possessed a reasonable suspicion of criminal activity justifying a forcible stop and detention.
Summary
Defendant Martinez appealed the denial of his motion to suppress vials of crack cocaine found on his person. The Court of Appeals affirmed the lower court’s decision, holding that the police officers possessed reasonable suspicion to stop and detain Martinez. The Court emphasized that its review was limited to whether the record supported the determination that the police had reasonable suspicion to believe Martinez was committing or had committed a crime. Because such support existed, the Court affirmed the denial of the suppression motion.
Facts
Police officers forcibly stopped and detained Martinez. A search incident to that stop revealed vials of crack cocaine in his hand and coat pockets. Martinez moved to suppress the evidence, arguing that the police lacked reasonable suspicion to justify the stop and search.
Procedural History
The trial court denied Martinez’s motion to suppress the evidence. The Appellate Division affirmed the trial court’s decision. An Associate Justice of the Appellate Division dissented, granting Martinez permission to appeal to the Court of Appeals.
Issue(s)
Whether the police officers had a reasonable suspicion that the defendant had committed or was committing a crime, thus justifying the forcible stop and detention.
Holding
Yes, because the determination that the police officers had reasonable suspicion was supported by the record.
Court’s Reasoning
The Court of Appeals emphasized that its review was limited to whether the determination of the mixed question of law and fact – whether the police officers had reasonable suspicion to support the forcible stop and detention – was supported by the record. Citing People v. Harrison, 57 NY2d 470, 477, the court stated that since the lower court’s determination was supported, the Court of Appeals’ review was concluded, and the order of the Appellate Division had to be affirmed. The court reiterated that only the application of the legal standard to the specific facts was at issue. The court did not detail the specific facts giving rise to the reasonable suspicion; however, the affirmance indicates the facts were sufficient to meet the reasonable suspicion standard. The decision highlights the limited scope of review for the Court of Appeals in cases involving mixed questions of law and fact, where the lower courts’ findings are supported by the record.