People v. Brosnan, 32 N.Y.2d 284 (1973)
Evidence of a crime, discovered during a lawful search of an automobile based on probable cause related to the vehicle itself, is admissible even if the probable cause originated from a separate crime.
Summary
Brosnan was convicted of robbery and assault. During a later arrest for a similar crime, a search of his car revealed evidence related to the prior crime. The New York Court of Appeals held that the search was lawful because the police had probable cause to believe the car was connected to the second crime, allowing the evidence from the first crime to be admitted. This ruling aligns with the automobile exception to the warrant requirement, permitting searches of vehicles when probable cause exists due to their mobility and the reduced expectation of privacy. The court emphasized that the search was justified by the connection of the vehicle to the crime, not solely as an incident to the arrest.
Facts
Dorothy Ringwood was robbed and assaulted on July 10, 1965.
On January 15, 1966, Brosnan was arrested for the robbery and assault of Diane Tiederman. Tiederman provided police with a detailed description of her assailant and the car used in the crime.
A police officer spotted Brosnan driving a car matching Tiederman’s description. Upon arrest, a search of the car revealed a woman’s handbag and coat believed to belong to Tiederman, as well as a knife.
A subsequent search of the car’s trunk at the police station uncovered a wallet and documents belonging to Ringwood, the victim of the prior robbery.
Procedural History
Brosnan was convicted of robbing and assaulting Dorothy Ringwood. He appealed, arguing that the evidence found in his car was obtained through an unlawful search and should have been suppressed. The People conceded that the consecutive sentences for robbery and grand larceny should have run concurrently.
Issue(s)
Whether the search of Brosnan’s car, which uncovered evidence related to a crime different from the one for which he was arrested, was a lawful search based on probable cause.
Holding
Yes, because the police had probable cause to believe that the car was an instrumentality of the crime for which Brosnan was arrested, justifying the search regardless of whether the evidence found related to a different crime.
Court’s Reasoning
The court relied on Chambers v. Maroney, 399 U.S. 42 (1970), which established that a warrantless search of an automobile is permissible when police have probable cause to believe the vehicle itself is connected to a crime. The court distinguished this case from situations where the search is solely incident to an arrest, emphasizing that the probable cause stemmed from the car’s use in the Tiederman crime. The court stated, “The car was so connected in ongoing relationship and direct instrumentality with the Tiederman crime, as it was reported and described to police, that its seizure and inspection without a warrant were justified on probable cause independently of association with defendant’s arrest.” Just as in Chambers, evidence of a separate crime found during a lawful search is admissible in the prosecution of that other crime.
The court further noted the consistency of this ruling with Carroll v. United States, 267 U.S. 132 (1925), which distinguished between the protections against search for a vehicle versus a home, recognizing the mobility of vehicles and the reduced expectation of privacy in them. The court cited People v. Lewis, 26 N.Y.2d 547, restating that “There must exist a reasonable belief that the search will produce the fruits, instrumentalities, contraband or evidence” related to the crime.
The court addressed the defendant’s claim of ineffective assistance of counsel, stating that such claims must be initially raised in the trial court, not on appeal. The court did, however, modify the judgment to mandate concurrent sentences for robbery and grand larceny.