People v. Copeland, 9 N.Y.2d 450 (1961)

A police officer may arrest a person without a warrant for a traffic infraction committed in the officer’s presence, and is not required to inform the person of the cause of arrest when the person is apprehended in the actual commission of the infraction.

Summary

Copeland was pulled over for speeding. The officer did not inform Copeland why he was being arrested, but took him to a justice of the peace where he was charged with speeding. Copeland argued the arrest was unlawful because the officer failed to inform him of the cause of the arrest. The New York Court of Appeals held that the arrest was lawful. The Court reasoned that because Copeland was actively committing the traffic infraction of speeding in the officer’s presence, the officer was not required to inform him of the reason for the arrest. The Court emphasized that traffic infractions are treated as misdemeanors for procedural purposes, including arrest.

Facts

A state trooper observed Copeland driving at a high speed and clocked him going 70-75 mph in a 50-mph zone.
The trooper stopped Copeland and took his driver’s license and registration.
When Copeland asked, “What did I do wrong?”, the trooper directed him to follow him to the judge.
At the judge’s house, the trooper filed an information charging Copeland with speeding.
Copeland pleaded not guilty but was convicted and fined $50 after a trial where he admitted exceeding the speed limit.

Procedural History

Copeland filed an action for false arrest seeking $10,000 in damages.
The trial court concluded the arrest was illegal because the trooper failed to inform Copeland of the cause of the arrest and instructed the jury to only consider damages.
The jury returned a verdict of $600.
The Appellate Division affirmed the judgment by a 3-2 vote.
The New York Court of Appeals granted leave to appeal.

Issue(s)

Whether a police officer must inform a person of the cause of arrest when the person is apprehended in the actual commission of a traffic infraction.

Holding

No, because when a person is apprehended in the actual commission of a crime, there is no need to inform him of the cause of his arrest, and traffic infractions are treated as misdemeanors for procedural purposes, including arrest.

Court’s Reasoning

Section 180 of the Code of Criminal Procedure states that an officer arresting without a warrant must inform the person of the cause of the arrest, “except when the person arrested is in the actual commission of a crime.” The court reasoned that the exception exists because “when a person is apprehended in the actual commission of a crime, there is, of course, no need to acquaint him with the cause of his arrest. The reasonable and necessary assumption… is that the offender caught in the act is fully aware of what he is doing and why he is being taken into custody.”

Copeland argued that speeding is a “traffic infraction” not a “crime” under the Vehicle and Traffic Law, and therefore the exception does not apply. The Court rejected this argument, explaining that the Vehicle and Traffic Law explicitly states that for the purposes of jurisdiction, traffic infractions “shall be deemed misdemeanors and all provisions of law relating to misdemeanors…shall apply to traffic infractions.” The court reasoned that it would be inconsistent to treat traffic infractions as misdemeanors for prosecution purposes, but not for arrest purposes. As the court stated, such a reading would be “inconsistent, fraught with practical difficulties and would defeat the apparent purpose of the Legislature in providing an orderly and consistent procedure for punishment of violators of the Vehicle and Traffic Law.”

The Court observed that to accept Copeland’s view would mean that a peace officer could never make an arrest for a traffic infraction without a warrant, even if the offense were committed in their presence. This would require officers to obtain a warrant from a magistrate before taking someone into custody for a traffic infraction, a consequence that would “hamper prompt and effective enforcement” of traffic laws.

The court concluded that a person committing an offense, whether a felony, misdemeanor, or traffic infraction, is aware of what they are doing. Therefore, an officer apprehending someone in the act of committing the offense need not state the obvious and inform the offender of the reason for the arrest.