88 N.Y.2d 534 (1996)

The police may impound a vehicle involved in a fatal accident for a warrantless safety inspection when that inspection is related in scope to the duty to investigate the facts surrounding the accident and the safety equipment on vehicles is normally subject to extensive government regulation.

Summary

The New York Court of Appeals held that police could impound a vehicle involved in a fatal accident and conduct a warrantless safety inspection. The defendant was charged with operating a vehicle with inadequate brakes after a fatal accident. The court reasoned that Vehicle and Traffic Law § 603 implicitly grants police the authority to impound vehicles for safety inspections to fulfill their investigatory duties. The court balanced the diminished expectation of privacy in a vehicle due to pervasive regulation with the state’s interest in public safety following a fatal accident, finding the inspection reasonable under the Fourth Amendment and the New York State Constitution.

Facts

The defendant’s vehicle was involved in a fatal accident with a bicyclist. Police informed the defendant that the vehicle was being impounded for a safety inspection. A mechanic inspected the vehicle and reported that the right rear brakes had “metal to metal contact.” The defendant was charged with operating a motor vehicle with inadequate brakes in violation of Vehicle and Traffic Law § 375(1) based on the inspection results. The defendant moved to suppress the evidence obtained from the safety inspection.

Procedural History

The Justice Court suppressed the evidence, holding that the inspection was an