People v. Morales, 82 N.Y.2d 420 (1993)

When police respond to a crime scene and a suspect drops an object accompanied by a metallic sound, the totality of the circumstances may provide reasonable suspicion for the police to handle the object.

Summary

In People v. Morales, the New York Court of Appeals upheld the Appellate Division’s order, finding the police had reasonable suspicion to handle the defendant’s jacket. The police responded to a report of a shooting in an apartment and found blood in the hallway. Upon entering the apartment, the defendant appeared startled and dropped his jacket, producing a metallic sound. The court reasoned that the circumstances, including the shooting report, the blood, and the metallic sound when the defendant dropped the jacket, collectively provided reasonable suspicion for the police to handle the jacket. The discovery of a gun in the jacket was therefore admissible.

Facts

Responding to a radio transmission about a shooting in a Brooklyn apartment, police officers found blood in the hallway near the elevator on the floor where the apartment was located. They heard arguing and loud music coming from the apartment. The defendant was inside the apartment and appeared startled upon seeing the officers. The defendant immediately dropped his jacket to the floor, and the officer heard a metallic “thunk.”

Procedural History

The trial court denied the defendant’s motion to suppress the gun found in the jacket. The Appellate Division affirmed the judgment. The New York Court of Appeals affirmed the Appellate Division’s order, upholding the finding that the police had reasonable suspicion.

Issue(s)

Whether the police officers had reasonable suspicion to handle the defendant’s jacket, which the defendant dropped right next to him.

Holding

Yes, because the totality of the circumstances, including the report of a shooting, the presence of blood, and the metallic sound upon the jacket hitting the floor, provided reasonable suspicion for the police to handle the jacket.

Court’s Reasoning

The Court of Appeals determined that the Appellate Division’s finding of reasonable suspicion was supported by the evidence in the record. The court emphasized that whether the police officers had reasonable suspicion involves a mixed question of law and fact. The court cited precedent that its review is limited when the record supports a determination of reasonable suspicion. The court highlighted the following facts as supporting the finding of reasonable suspicion: the police were responding to a report of a shooting; they discovered blood in the hallway; the defendant appeared startled upon seeing the officers; and a metallic “thunk” was heard when the jacket was dropped. The court effectively applied the totality of the circumstances test to assess the reasonableness of the officer’s actions. The court implicitly balanced the individual’s right to privacy against the legitimate concerns for officer safety and crime prevention, concluding that the specific facts justified the limited intrusion of handling the jacket. There were no dissenting or concurring opinions.