97 N.Y.2d 341 (2001)
A traffic stop is lawful if supported by probable cause, regardless of the officer’s primary motivation or what a reasonable officer would have done under the circumstances.
Summary
The New York Court of Appeals addressed whether a traffic stop based on probable cause is invalid if the officer’s primary motivation was to investigate a different matter. An unidentified complainant reported a reckless driver in a red Suzuki. A state trooper observed a matching vehicle with a faulty muffler. The trooper stopped the vehicle, and based on observations, sobriety tests, and admissions, arrested the defendant for driving while intoxicated. The Court of Appeals held the stop was lawful because the trooper had probable cause to believe the defendant violated the Vehicle and Traffic Law, irrespective of the trooper’s subjective motivation.
Facts
An unidentified person reported a reckless driver operating a red Suzuki with its top down or removed to the authorities. A State Trooper located a Suzuki matching that description. While following the Suzuki, the trooper noticed that it had a faulty muffler, a violation of Vehicle and Traffic Law § 375(31). The trooper then initiated a traffic stop.
Procedural History
The defendant was arrested for driving while intoxicated and subsequently indicted and convicted of felony driving while intoxicated. The Appellate Division reversed the conviction and granted the defendant’s suppression motion. The Appellate Division reasoned that the trooper used the traffic infraction as a pretext to investigate the reckless driving complaint. The Court of Appeals reversed the Appellate Division’s order, denied the defendant’s suppression motion, and remitted the case to the Appellate Division for consideration of the facts.
Issue(s)
Whether a traffic stop supported by probable cause is unlawful if the officer’s primary motivation was to investigate a matter unrelated to the traffic violation.
Holding
No, because provided a traffic stop is supported by probable cause, “neither the primary motivation of the officer nor a determination of what a reasonable traffic officer would have done under the circumstances is relevant.”
Court’s Reasoning
The Court of Appeals relied on an objective test, focusing solely on whether probable cause existed for the traffic stop. The Court stated, “provided a traffic stop is supported by probable cause, ‘neither the primary motivation of the officer nor a determination of what a reasonable traffic officer would have done under the circumstances is relevant’.” The court emphasized that the suppression court’s undisturbed finding was that the trooper had probable cause to believe the defendant committed a muffler violation. The court explicitly rejected the Appellate Division’s focus on the trooper’s subjective motivation. This ruling provides law enforcement with clear guidance: if probable cause exists for a traffic violation, the stop is lawful, regardless of the officer’s underlying intent. The court in this case does not discuss dissenting or concurring opinions.