People v. Sanders, 25 N.Y.3d 774 (2015)
Under the plain view doctrine, an officer can seize an object without a warrant if the officer is lawfully in a position from which to view the object, has lawful access to the object, and the object’s incriminating nature is immediately apparent, supported by probable cause that the object is the instrumentality of a crime.
Summary
The New York Court of Appeals addressed the legality of a warrantless seizure of a shooting victim’s clothing from a hospital. The court held that the seizure violated the Fourth Amendment because the police lacked probable cause to believe the clothing was evidence of a crime. The court emphasized that the plain view doctrine requires not only lawful observation but also probable cause to believe the item viewed is evidence. The court found the officer’s observations, prior to the seizure, insufficient to establish the required probable cause, thus rendering the seizure unconstitutional. This case underscores the critical importance of probable cause in justifying warrantless seizures, even when an item is in plain view.
Facts
The defendant walked into a hospital seeking treatment for a gunshot wound. Police were notified, and an officer responded. The officer was directed to the defendant’s clothes, which were in a clear plastic bag. The officer observed the clothes (jeans, boxers, sneakers) and seized the bag. Based on observations, the police believed the defendant accidentally shot himself. The defendant was charged with weapons possession. Prior to trial, the defendant moved to suppress the clothing as the product of an illegal warrantless seizure. The trial court denied the motion, and the defendant was subsequently convicted.
Procedural History
The defendant moved to suppress the evidence, which was denied. The defendant was convicted at trial. The Appellate Division affirmed the conviction, ruling the seizure was permissible under the plain view doctrine. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the seizure of the defendant’s clothing from the hospital violated the Fourth Amendment’s protection against unreasonable searches and seizures.
Holding
Yes, because the police lacked probable cause to believe the clothing was evidence of a crime, rendering the seizure unconstitutional.
Court’s Reasoning
The Court of Appeals reiterated the well-established principle that warrantless searches and seizures are presumptively unreasonable under the Fourth Amendment, subject to specific exceptions. The court focused on the