People v. Banks, 85 N.Y.2d 556 (1995)
Once the justification for a traffic stop is exhausted, continued detention of the vehicle and its occupants is unlawful unless reasonable suspicion of additional criminal activity arises.
Summary
Banks was a passenger in a vehicle stopped for a seatbelt violation. After the initial stop, the officer, lacking reasonable suspicion of other criminal activity, continued to detain the vehicle’s occupants while awaiting a backup officer to conduct a search. The New York Court of Appeals held that the extended detention was unlawful because the justification for the initial stop (the seatbelt violation) had been exhausted, and the officer lacked reasonable suspicion to prolong the seizure. Consequently, the evidence found during the subsequent search was suppressed.
Facts
Trooper Cuprill stopped a vehicle for a seat belt violation. Banks was a passenger. The driver produced a suspicious license. Both the driver and Banks gave differing stories regarding their trip. After running a license and stolen vehicle check that came back negative, the trooper prepared traffic tickets but decided to search the vehicle instead. He called for backup and detained Banks and the driver until backup arrived.
Procedural History
The trial court denied Banks’ motion to suppress the evidence. The Appellate Division affirmed. The New York Court of Appeals reversed, finding the detention unlawful and ordering suppression of the evidence.
Issue(s)
Whether the police officer’s continued detention of the vehicle and its occupants, after the initial justification for the traffic stop had been exhausted, was lawful in the absence of reasonable suspicion of additional criminal activity.
Holding
No, because once the purpose of the initial traffic stop (issuing a ticket for a seatbelt violation) was concluded, the continued detention constituted an unlawful seizure under the Fourth Amendment in the absence of reasonable suspicion of further criminal activity.
Court’s Reasoning
The Court of Appeals reasoned that a traffic stop is a limited seizure, justified only as long as reasonably related in scope to the initial circumstances. Once the justification for the stop is exhausted (e.g., by issuing a ticket), any further detention must be supported by reasonable suspicion of other criminal activity. The Court found that the innocuous discrepancies in the stories given by Banks and the driver, along with Banks’ nervousness, did not amount to reasonable suspicion. The Court emphasized that the trooper admitted he delayed issuing the tickets in order to conduct a search. Because the consent to search was obtained during an illegal detention, it was not valid. The Court cited People v. Milaski, 62 N.Y.2d 147, noting that once the license and vehicle checks came back negative and the tickets were prepared, the justification for the stop ended. As the court noted, “The Trooper nevertheless retained their licenses, effectively forcing them to remain at the scene while he awaited the appearance of the backup Trooper he had requested. This continued involuntary detention of defendant and Jones and their vehicle constituted a seizure in violation of their constitutional rights”. The court also stated that “under no rational view of the evidence at the suppression hearing can it be concluded that Jones’ consent was acquired by means sufficiently distinguishable from the taint of illegal detention”.