People v. Adrion, 82 N.Y.2d 628 (1993)
Probable cause for an arrest can be established through an officer’s independent observations, even if the initial information leading to the observation came from a confidential informant; a Darden hearing is not required if probable cause exists independently of the informant’s tip.
Summary
Adrion was arrested after a confidential informant provided information to the police about stolen luggage at a specific location. An officer went to the location and arrested Adrion after finding boxes. The New York Court of Appeals held that because the People could not establish probable cause without the informant’s testimony, the Appellate Division’s reinstatement of the prosecution was reversed. This case stands in contrast to cases where police make independent observations that establish probable cause separate from informant information.
Facts
A confidential informant told the police that stolen luggage could be found in a specific location.
A police officer went to that location and saw boxes.
The police officer arrested Adrion.
Procedural History
The trial court’s decision is not included.
The Appellate Division reinstated the prosecution.
The New York Court of Appeals reversed the Appellate Division’s decision.
Issue(s)
Whether probable cause to arrest Adrion existed independently of the confidential informant’s information.
Holding
No, because the People could not establish probable cause without the testimony of the confidential informant.
Court’s Reasoning
The Court of Appeals distinguished this case from situations where probable cause can be established by the independent observations of a police officer. The court emphasized that in this case, the officer’s actions (going to the location and seeing boxes) were directly based on the informant’s tip, and without the informant’s information, there was no independent basis for probable cause. The court compared the instant case to People v. Darden, stating that, similarly, the testimony of the confidential informant was necessary to establish probable cause. Because the People could not establish probable cause without the testimony of the confidential informant, this Court reversed the reinstatement of the prosecution by the Appellate Division.