People v. Turriago, 90 N.Y.2d 77 (1997)
The inevitable discovery doctrine is an exception to the exclusionary rule, allowing admission of secondary evidence if the prosecution proves a very high degree of probability that the evidence would have been discovered through lawful means, independent of the illegal conduct.
Summary
The New York Court of Appeals addressed the application of the inevitable discovery doctrine in the context of a murder case where evidence was initially obtained through a consent search later challenged as unlawful. The court held that while the Appellate Division erred in rejecting the inevitable discovery doctrine as a matter of law, the trial court should determine whether a valid inventory search would have inevitably led to the discovery of the victim’s body and other incriminating evidence. The Court clarified the distinction between primary and secondary evidence in applying the inevitable discovery rule, stating that while primary evidence is inadmissible, secondary evidence is admissible if it inevitably would have been discovered.
Facts
Defendant was stopped for speeding while driving a U-Haul van. State Troopers requested and received consent to search the van because it was hunting season and they were looking for illegal hunting activity. The search revealed the body of a murder victim in a steamer trunk. Defendant made incriminating statements after being confronted with evidence obtained from his accomplices. Police obtained search warrants for defendant’s apartments and recovered additional evidence, including the murder weapon which was retrieved from the Hudson River. The defendant moved to suppress the evidence.
Procedural History
The Supreme Court (trial court) denied the motion to suppress, finding the consent to search was voluntary, and defendant was convicted. The Appellate Division reversed, holding the consent was invalid because police lacked a founded suspicion to request the search and rejecting the inevitable discovery doctrine. The People appealed to the Court of Appeals.
Issue(s)
Whether the Appellate Division erred in rejecting, as a matter of law, the application of the inevitable discovery doctrine to the incriminating evidence obtained by the police.
Holding
Yes, because the Appellate Division erred in rejecting the inevitable discovery doctrine as a matter of law. The case was remitted to the Supreme Court to determine whether the evidence would have been inevitably discovered through a lawful inventory search.
Court’s Reasoning
The Court of Appeals held that the inevitable discovery doctrine is a valid exception to the exclusionary rule. The court emphasized that the prosecution must demonstrate a “very high degree of probability” that the evidence would have been discovered through lawful means. The Court cited People v. Fitzpatrick, stating that evidence is admissible “where the normal course of police investigation would, in any case, even absent the illicit conduct, have inevitably led to such evidence.” The Court also referenced Nix v. Williams, noting the exclusionary rule should not put the prosecution in a worse position than it would have been in absent police misconduct. The court distinguished between primary evidence (obtained directly from the illegal conduct), which is inadmissible, and secondary evidence (obtained as a result of the primary evidence), which can be admissible if its discovery was inevitable. Here, the court found that the troopers testified that absent consent, the vehicle would have been impounded due to the defendant’s suspended license and then an inventory search conducted. The Court quoted 5 LaFave, Search and Seizure, stating “Circumstances justifying application of the ‘inevitable discovery’ rule are most likely to be present * * * where the circumstances are such that, pursuant to some standardized procedures or established routine a certain evidence-revealing event would definitely have occurred later”. Because the suppression court ruled for the People on voluntariness of consent, it did not determine the factual issues related to the People’s inevitable discovery argument. The Court of Appeals thus remitted the case to the Supreme Court for that determination.