People v. Jennings, 54 N.Y.2d 518 (1981)

An arrest is invalid, and evidence obtained as a result must be suppressed, when the arresting officer relies on criminal justice system records that, through the fault of the system, contain incorrect information about an outstanding warrant.

Summary

Jennings was arrested based on a National Crime Information Center (NCIC) teletype indicating an active parole violation warrant. A search incident to the arrest uncovered stolen property. However, the warrant had been executed and vacated months before the arrest, and the New York State Identification and Intelligence System (NYSIIS) had been notified. The New York Court of Appeals held the arrest invalid because it was based on incorrect information in the criminal justice system records, requiring suppression of the evidence. The court emphasized that probable cause must be objectively reasonable and that an officer’s good faith cannot validate an arrest based on an invalid warrant.

Facts

In September 1978, police circulated a flyer about Jennings, who was suspected of burglaries. Officer Enright stopped Jennings for traffic violations. Enright requested a warrant check through Hempstead Police Headquarters. Hempstead headquarters relayed the information to NCIC and NYSIIS. The teletype response indicated an active parole violation warrant issued in November 1977. The warrant had been executed in January 1978, and NYSIIS was notified. Furthermore, a Supreme Court order vacated the warrant in June 1978. Based on the teletype, Enright arrested Jennings. A search incident to arrest revealed stolen jewelry and other items.

Procedural History

Jennings was indicted for burglary. He moved to suppress the evidence, palmprint, and statement based on Fourth Amendment grounds. The trial court denied the motion, and Jennings was convicted. The Appellate Division affirmed the conviction. The New York Court of Appeals reversed, granting the motion to suppress.

Issue(s)

Whether an arrest based on a computer record indicating an active warrant, when that warrant has been executed and vacated, is valid and whether evidence seized incident to that arrest is admissible.

Holding

No, because the arrest was based on incorrect information in the criminal justice system records, making it invalid, and the evidence seized must be suppressed as a result.

Court’s Reasoning

The Court relied on the “fellow officer” rule established in Whiteley v. Warden, which states that an officer can rely on information from another officer, but if the underlying warrant is invalid, the evidence seized is inadmissible. The court rejected the People’s argument to distinguish between an invalidly issued warrant and a validly issued but vacated warrant, stating, “In each case, police intrude upon protected Fourth Amendment interests under the purported authority of a warrant which is subsequently revealed to have furnished, at the time of the intrusion, no justification for such police conduct.” The Court further rejected the argument that Officer Enright’s “good faith” reliance on the warrant made the exclusionary rule inapplicable. The Court stated, “An assessment of probable cause turns on what was reasonably and objectively in the mind of law enforcement authorities. It does not turn on such subjective considerations as the absence of malice against a suspect, the lack of intent to violate constitutional rights…” The Court reasoned that the good faith of the officer does not validate an arrest based on a warrant that had been vacated months before the arrest. The Court emphasized the importance of accurate record-keeping within the criminal justice system to protect Fourth Amendment rights. The inevitable discovery argument was rejected because the officer conceded he would not have arrested the defendant absent the warrant information.