People v. Tejada, 81 N.Y.2d 819 (1993)

The scope of a Mapp hearing is limited to whether evidence was obtained in violation of a defendant’s constitutional rights, and does not extend to determining ultimate issues of fact, such as whether the defendant possessed the contraband in question; also, police may enter a premises without a warrant when they are in pursuit of a suspect in a shooting.

Summary

The New York Court of Appeals held that the Supreme Court erred in suppressing contraband based on the defendant’s claims at the suppression hearing. The Court clarified that a Mapp hearing’s purpose is to determine if evidence was obtained in violation of constitutional rights, not to resolve factual disputes about possession of contraband. Further, the Court upheld the Appellate Division’s finding that the police properly entered the defendant’s apartment in pursuit of a shooting suspect. The Court could not review the security sweep justification as it was not properly raised and decided below.

Facts

Detectives entered the defendant’s apartment while pursuing a suspect in a shooting, whom they knew by sight. After entering, they discovered contraband. The defendant testified at the suppression hearing that he never touched the contraband and that the police planted it on him after searching the apartment. The defendant argued this showed a lack of probable cause for his arrest. The defense also challenged the legality of the officers’ search under the Fourth Amendment.

Procedural History

The Supreme Court suppressed the contraband. The Appellate Division reversed, concluding that the Supreme Court erred in suppressing the evidence. The case then went to the New York Court of Appeals.

Issue(s)

1. Whether the Supreme Court erred in suppressing contraband based on factual claims made by the defendant at the suppression hearing regarding his lack of possession and police planting of evidence.
2. Whether the scope of a Mapp hearing extends to determining the ultimate issue of whether the defendant was actually in possession of the contraband.
3. Whether the police’s entry into the defendant’s apartment was proper under the Fourth Amendment.

Holding

1. Yes, the Supreme Court erred because the defendant’s factual claims, even if true, did not directly address the legality of the apartment search under the Fourth Amendment.
2. No, because the issue before the court in the Mapp hearing is limited to whether the evidence was obtained in violation of the defendant’s constitutional rights, not whether the contraband belonged to the defendant.
3. Yes, because the detectives properly entered the apartment in pursuit of a suspect in a shooting, who was known to them by sight.

Court’s Reasoning

The Court reasoned that the defendant’s claims regarding lack of possession and police misconduct, while potentially relevant to guilt or innocence, did not impact the legality of the search itself. The Mapp hearing is specifically designed to address constitutional violations in obtaining evidence, not to resolve factual disputes about possession. The Court emphasized that defense counsel did not explain how these factual claims impacted the legality of the search under the Fourth Amendment. The court cited People v. Burr, 70 N.Y.2d 354, 360-361, affirming that police entry was justified based on the emergency circumstances, as they were in pursuit of a known suspect. The court stated, “The issue before the court in the Mapp hearing was limited to whether the evidence was obtained in violation of defendant’s constitutional rights, not whether the contraband found in the apartment belonged to someone other than defendant.” The Court declined to review the Appellate Division’s security sweep justification, noting that this issue was not properly raised at the initial hearing, citing CPL 470.05 [2]. This case clarifies that suppression hearings have a limited scope, focused solely on the constitutionality of the evidence gathering, and provides a practical reminder to defense counsel to clearly articulate how factual claims relate to constitutional violations. It reinforces the emergency exception to the warrant requirement in cases of hot pursuit.