New York Law Review

Tag: People v. Morales

  • People v. Morales, 20 N.Y.3d 240 (2012): Defining ‘Intent to Intimidate or Coerce a Civilian Population’ in Terrorism Statutes

    People v. Morales, 20 N.Y.3d 240 (2012)

    New York’s terrorism statute, Penal Law Article 490, was not intended to elevate gang-on-gang violence to the level of terrorism, requiring a showing that the defendant’s actions were designed to intimidate or coerce a broad civilian population, not merely rival gang members.

    Summary

    Edgar Morales, a member of the “St. James Boys” gang, was convicted of terrorism for a shooting during a gang fight that resulted in the death of a child and the paralysis of another individual. The New York Court of Appeals reversed the terrorism convictions, holding that the intent to intimidate or coerce a civilian population, as required by the terrorism statute, was not met. The court reasoned that the statute was aimed at acts with a broader terroristic purpose and not simply gang-related violence. Additionally, the court ordered a new trial on the underlying offenses due to prejudicial spillover from the terrorism charges.

    Facts

    Defendant Edgar Morales, a member of the St. James Boys (SJB) gang, attended a christening party. SJB members identified Miguel, who they believed belonged to a rival gang, and planned to assault him. Morales obtained a revolver and agreed to shoot Miguel if necessary. A fight ensued, and Morales fired five shots, paralyzing Miguel and fatally wounding a 10-year-old girl. Morales and other SJB members fled the scene, disposing of the gun and shell casings.

    Procedural History

    Morales was indicted on 70 counts, including crimes of terrorism and conspiracy. The Supreme Court denied Morales’s motion challenging the sufficiency of evidence for the terrorism charges. The jury convicted Morales of three terrorism charges and second-degree conspiracy. The Appellate Division modified, reducing the terrorism convictions to the underlying offenses and the conspiracy conviction to a lesser charge. The New York Court of Appeals granted leave to appeal.

    Issue(s)

    1. Whether the phrase “intent to intimidate or coerce a civilian population” in Penal Law § 490.25 encompasses gang-related violence targeted at rival gang members or a subset of the general population.

    2. Whether the introduction of evidence related to the terrorism charges unduly prejudiced the jury’s ability to fairly adjudicate guilt or innocence on the underlying offenses.

    Holding

    1. No, because the New York legislature did not intend to elevate gang-on-gang violence to the status of terrorism.

    2. Yes, because the volume of proof regarding unrelated assaults, murders, and other offenses created a reasonable possibility that the jury’s findings were prejudicially influenced.

    Court’s Reasoning

    The Court of Appeals reasoned that the terrorism statute was enacted to address acts with a broader terroristic purpose, citing examples like the September 11th attacks and other high-profile terrorist incidents. The Court found that applying the terrorism statute to gang-on-gang violence would trivialize the concept of terrorism. "The concept of terrorism has a unique meaning and its implications risk being trivialized if the terminology is applied loosely in situations that do not match our collective understanding of what constitutes a terrorist act."

    The court considered the legislative history, noting that the definitional provisions of Penal Law Article 490 were drawn from the federal definition of “international terrorism”. The court stated that federal antiterrorism statutes were designed to criminalize acts such as “the detonation of bombs in a metropolitan area” or “the deliberate assassination of persons to strike fear into others to deter them from exercising their rights”—conduct that is not akin to the serious offenses charged in this case.

    Regarding the cross-appeal, the court determined that the introduction of evidence related to numerous alleged criminal acts committed by SJB members over three years, which would have been inadmissible without the terrorism charge, prejudiced the jury. The Court stated that "[w]ithout the aura of terrorism looming over the case, the activities of defendant’s associates in other contexts would have been largely, if not entirely, inadmissible." This spillover effect required reversal and a new trial on the underlying offenses.

  • People v. Morales, 82 N.Y.2d 420 (1993): Justification for Police Handling of Dropped Object

    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.

  • People v. Morales, 80 N.Y.2d 450 (1992): Defendant’s Right to Presence at Child Witness Competency Hearing

    People v. Morales, 80 N.Y.2d 450 (1992)

    A defendant does not have a constitutional or statutory right to be present at a preliminary competency hearing to determine whether a child witness understands the nature of an oath, as such a hearing is ancillary to the main trial and the defendant’s presence is unlikely to contribute to a more reliable determination of competency.

    Summary

    Edwin Morales was convicted of rape and sodomy against a nine-year-old child, R.H. Prior to R.H.’s testimony, the trial court conducted a competency hearing outside the defendant’s presence to determine if R.H. understood the nature of an oath, as required by CPL 60.20(2). The court allowed defense counsel and the prosecutor to attend, but not the defendant. The Court of Appeals affirmed the conviction, holding that excluding the defendant from the competency hearing did not violate his constitutional or statutory rights, as the hearing was unrelated to the substantive issues at trial, and the defendant’s presence would not have materially contributed to the competency determination. The court reasoned that the core purpose of CPL 60.20 hearing is to assess testimonial capacity, making it distinct from the trial’s central concerns.

    Facts

    Edwin Morales was indicted for rape, sodomy, and other crimes against R.H. and E.T., children he lived with. As R.H. was nine years old, the trial court was required to determine if she understood the nature of an oath before allowing her to give sworn testimony. The trial court conducted a competency inquiry after the trial had commenced, but outside the presence of the jury. The judge excluded Morales from the hearing, stating that the proceeding was “not something that your client has a right to be present at.”

    Procedural History

    The jury convicted Morales of rape and sodomy. Morales appealed, arguing that his constitutional and statutory rights to be present at trial were violated when he was barred from the competency hearing. The Appellate Division unanimously rejected Morales’ claims. The New York Court of Appeals affirmed the Appellate Division’s decision.

    Issue(s)

    Whether a defendant has a constitutional or statutory right to be present when the trial court preliminarily examines a child witness to determine whether she understands the nature of an oath?

    Holding

    No, because the competency hearing’s purpose is to determine a witness’ testimonial capacity, making it unrelated to the basic issues at trial, and the defendant failed to show that his presence would have ensured a more reliable competency determination.

    Court’s Reasoning

    The Court of Appeals held that the defendant’s exclusion from the CPL 60.20 hearing did not violate his federal due process rights. Citing Snyder v. Massachusetts, the Court noted that a defendant’s presence is required only to the extent that a fair and just hearing would be thwarted by his absence. The Court relied on Kentucky v. Stincer, which held that a competency hearing is not related to the witnesses’ substantive testimony, and the defendant had not demonstrated that his presence would have been useful in ensuring a more reliable determination of competency. The court dismissed the defendant’s argument that the hearing involved substantive testimony, finding that R.H.’s brief statement about the abuse did not create a substantial relationship to the opportunity to defend at trial. The Court also rejected the argument that the defendant’s relationship with R.H. could have made his presence useful, as the defendant presented no evidence that his knowledge of the child’s background could have resulted in a more assured determination of competency.

    The Court further held that the defendant was not deprived of his right to be present under New York State law (CPL 260.20). The Court acknowledged that the statute guarantees the defendant’s right to be present at all important stages of the trial. However, the Court clarified that while a defendant has an unfettered right to attend trial, they only have a qualified right to attend ancillary proceedings. Analyzing prior decisions, the Court reasoned that a CPL 60.20 hearing is not a core part of the trial and could have been conducted pretrial. Since it related to a witness’ testimonial capacity, it was a legal determination unrelated to trial issues.

    The court distinguished the case from those where the defendant’s presence was required because they had something valuable to contribute, such as knowledge of errors in a rap sheet (People v. Dokes) or inconsistencies in a witness’ testimony (People v. Anderson). Here, the hearing concerned a witness’s testimonial capacity, a legal determination unrelated to trial issues. Quoting Snyder v. Massachusetts, the Court concluded that the defendant’s presence at the competency hearing would have been “useless, or the benefit but a shadow.”

  • People v. Morales, 37 N.Y.2d 262 (1975): Admissibility of Prior Identification Testimony

    People v. Morales, 37 N.Y.2d 262 (1975)

    Prior identification of a defendant is admissible at trial when the identifying witness observed the defendant at the crime scene, previously identified the defendant, and is unable to make a present in-court identification.

    Summary

    The New York Court of Appeals addressed the admissibility of prior identification testimony under CPL 60.25 when the identifying witness could not make a present in-court identification. The Court held that the testimony of a police officer confirming the pretrial identification of the defendant by the witness was properly admitted because all three preconditions of CPL 60.25(2) were met. The Court also found that the showup identification procedure was not unnecessarily suggestive, as it was deemed accidental and spontaneous, thus upholding the lower court’s decision.

    Facts

    A witness, Grant, observed an individual at a crime scene. Later, at the police station, Grant saw and recognized the defendant, Morales, as the person he had observed at the scene. At trial, Grant was unable to state with present recollection whether Morales was the person he had seen. Officer Moroney was present when Grant identified Morales at the station house.

    Procedural History

    The suppression court found the showup was not unnecessarily suggestive and denied the motion to suppress the identification. The Appellate Division affirmed this finding, characterizing the showup as “accidental” and the identification as spontaneous. The case then reached the New York Court of Appeals.

    Issue(s)

    1. Whether the testimony of Officer Moroney confirming the pretrial identification of the appellant by the witness Grant was properly admissible at trial under CPL 60.25(2)?

    2. Whether the procedures followed by the police in connection with the showup at which Grant identified the appellant were unconstitutionally suggestive?

    Holding

    1. Yes, because all three preconditions to the application of CPL 60.25 (subd 2) were met.

    2. No, because the showup was found to be accidental and the identification spontaneous and untainted by any untoward police conduct.

    Court’s Reasoning

    The Court of Appeals reasoned that all three conditions of CPL 60.25(2) were satisfied, making the officer’s testimony admissible. First, the identifying witness observed the person claimed to be the defendant at the crime scene (CPL 60.25, subd 1, par [a], cl [i]). Second, the identifying witness, in the presence of Officer Moroney, observed a person whom he recognized as the subject of his on-the-scene observation (CPL 60.25, subd 1, par [a], cl [ii]). Third, the identifying witness was unable at trial to state, on the basis of present recollection, whether or not appellant was the person in question (CPL 60.25, subd 1, par [a], cl [iii]).

    Regarding the constitutionality of the showup, the Court deferred to the Appellate Division’s finding that the showup was “accidental” and the identification spontaneous. Citing People v. Gruttola, 43 NY2d 116, 122, the Court stated that such a determination, affirmed by the Appellate Division, is beyond their power of review. The court emphasized the absence of “untoward police conduct” that might have tainted the identification.

    The court implicitly reinforced the importance of spontaneous identifications made without undue influence from law enforcement, suggesting that such identifications are more reliable and less susceptible to constitutional challenges. The ruling emphasizes adherence to statutory requirements for the admissibility of prior identification testimony and deference to lower court findings on factual matters related to identification procedures.

  • People v. Morales, 42 N.Y.2d 129 (1977): Permissible Scope of Investigatory Detention Based on Reasonable Suspicion

    People v. Morales, 42 N.Y.2d 129 (1977)

    Law enforcement officials may detain an individual upon reasonable suspicion for questioning for a reasonable and brief period of time under carefully controlled conditions, protecting the individual’s Fifth and Sixth Amendment rights.

    Summary

    Melvin Morales was convicted of first-degree murder. The Court of Appeals initially upheld the conviction, finding that although the police lacked probable cause for arrest, they had reasonable suspicion to detain Morales for questioning. The U.S. Supreme Court vacated and remanded for a hearing to determine if there was probable cause, voluntary consent, or if the confession was a product of illegal detention. After a hearing, the trial court upheld the confession’s admissibility, finding probable cause and consent. The Appellate Division affirmed. The Court of Appeals affirmed, holding that there was no probable cause, but reaffirmed the principle allowing brief detention based on reasonable suspicion and also found the defendant consented to the police detention.

    Facts

    Addie Brown was murdered in her apartment building. Police learned that Melvin Morales, a narcotics addict who frequented the building, had been present at the time of the murder and then disappeared. Morales’ mother, a tenant, informed him police wanted to question him, and he agreed to meet them at her workplace. Police, who were staking out the premises, approached Morales, who said he knew they wanted to speak with him. He was taken to the precinct and confessed to the murder within 15 minutes after being advised of his rights.

    Procedural History

    Morales was convicted of first-degree murder, and the Appellate Division affirmed. The New York Court of Appeals sustained the conviction, holding a suspect may be detained on reasonable suspicion for questioning. The U.S. Supreme Court vacated the judgment and remanded for an evidentiary hearing. On remand, the trial court found the confessions admissible. The Appellate Division affirmed. Morales appealed to the New York Court of Appeals.

    Issue(s)

    1. Whether the police had probable cause to arrest Morales at the time he was taken into custody.
    2. Whether the principle allowing detention based on reasonable suspicion, as established in the first appeal, was undermined by Brown v. Illinois and People v. Martinez.
    3. Whether Morales voluntarily consented to police detention.

    Holding

    1. No, because the police did not possess reasonably trustworthy information sufficient to warrant a prudent man to believe that defendant had committed the crime.
    2. No, because those cases involved illegal arrests, while Morales’ detention was permissible based on reasonable suspicion.
    3. Yes, because the hearing court’s finding of consent was supported by the record and affirmed by the Appellate Division.

    Court’s Reasoning

    The court found that the additional evidence presented at the supplemental hearing (a witness seeing Morales near the building before the murder) was cumulative and did not establish probable cause. The court reaffirmed its prior holding that law enforcement officials may detain an individual upon reasonable suspicion for questioning for a brief period under controlled conditions. The court distinguished Brown v. Illinois, where the arrest was illegal because police lacked any basis for suspicion and were on an “expedition for evidence.” In contrast, the police investigation of Morales established a “checkerboard square” of circumstantial evidence pointing at him. Citing People v. De Bour, the court noted that an individual’s right to be free from official interference is not absolute. The court also found an alternative basis for its holding: that Morales consented to the police detention. Although the voluntariness of the consent was disputable, the trial court’s finding was supported by the record and therefore could not be upset.

  • People v. Morales, 37 N.Y.2d 262 (1975): Retroactivity of Unconstitutional Notice-of-Alibi Statute

    People v. Morales, 37 N.Y.2d 262 (1975)

    When a statute preventing a defendant from calling an alibi witness is later declared unconstitutional, that ruling applies retroactively on direct appeal, requiring reversal of the conviction if the alibi witness was improperly excluded.

    Summary

    The New York Court of Appeals addressed whether the unconstitutionality of a notice-of-alibi statute, which prevented the defendant from calling an alibi witness, should be applied retroactively on direct appeal. Morales was convicted of selling narcotics, but the trial court had barred an alibi witness because the defense failed to include her name on the pre-trial witness list as required by CPL 250.20. The Court of Appeals held that the statute’s unconstitutionality, as established in Wardius v. Oregon, applied retroactively because the trial occurred before Wardius, the witness was actually excluded, and the case was on direct appeal, thus warranting a new trial.

    Facts

    Detective Webster, an undercover officer, allegedly bought heroin from Morales. Webster signaled his backup team, who observed the interaction. Webster wrote a detailed description of Morales, including his clothing and a fictitious name derived from his goatee. Later, Webster returned to the area, spotted Morales, and directed the backup team to arrest him. Webster viewed Morales at the police precinct about six hours after the arrest, identifying him through a two-way mirror.

    Procedural History

    Morales was indicted for selling and possessing narcotics. At trial, Webster identified Morales. Morales presented an alibi defense but was prevented from calling a witness whose name was not on the pre-trial list, based on CPL 250.20. The Appellate Division reversed Morales’ conviction, citing the unconstitutionality of the notice-of-alibi statute and the admission of the police officer’s testimony regarding the station house viewing. The People appealed to the New York Court of Appeals.

    Issue(s)

    Whether a ruling that a notice-of-alibi statute is unconstitutional should be applied retroactively on direct appeal when the defendant was prevented from calling an alibi witness due to non-compliance with the statute.

    Holding

    Yes, because the unconstitutionality of the notice-of-alibi statute should be applied retroactively on direct appeal where the defendant was prevented from calling an alibi witness.

    Court’s Reasoning

    The Court reasoned that the concept of retroactivity, while complex, generally allows cases on direct appeal to benefit from newly pronounced law. Quoting Wardius v. Oregon, the Court emphasized that “discovery must be a two-way street. The State may not insist that trials be run as a ‘search for the truth’ so far as defense witnesses are concerned, while maintaining ‘poker game’ secrecy for its own witnesses.” Unlike People v. Bush, where the defendant had complied with the statute, Morales was actually prevented from calling a witness. The Court applied the criteria from Desist v. United States, considering (a) the purpose of the new standard, (b) reliance on the old standard, and (c) the effect of retroactive application. The Court found that the due process standard profoundly affected the fact-finding process, as it directly impacted the ability to present evidence. The Court noted the Sixth Amendment’s guarantee to call witnesses and its coupling with the right to counsel, decisions concerning which are commonly deemed retroactive. Furthermore, the Court found no significant reliance on the notice-of-alibi statute by law enforcement authorities. The Court also addressed the station house viewing by Webster, finding it proper because it was not for initial identification but to confirm the arrest of the correct person, consistent with good police work and ensuring the expeditious release of innocent suspects. The court affirmed the Appellate Division’s order for a new trial, but clarified that the station house viewing was admissible.

  • People v. Morales, 37 N.Y.2d 262 (1975): Applying Chimel’s Search Incident to Arrest Rule Retroactively

    People v. Morales, 37 N.Y.2d 262 (1975)

    The rule established in Chimel v. California regarding the permissible scope of a search incident to a lawful arrest applies to searches conducted after June 23, 1969, the date of the Chimel decision, even if the trial occurred later.

    Summary

    This case addresses the retroactive application of the Supreme Court’s decision in Chimel v. California, which narrowed the permissible scope of a search incident to a lawful arrest. The New York Court of Appeals held that the Chimel rule applies to searches conducted after the Chimel decision date, regardless of when the trial took place. This decision aligns New York’s application of the rule with the Supreme Court’s stance to ensure consistency and avoid establishing a different timeline for the rule’s application within New York State.

    Facts

    The specific facts of Morales’ arrest and the search conducted are not detailed in this per curiam opinion, as the primary focus is on the broader legal question of Chimel‘s retroactive application. The core issue revolves around whether evidence seized during a search, potentially exceeding the scope permitted by Chimel, should be suppressed.

    Procedural History

    The defendant moved to suppress evidence, likely arguing the search exceeded the permissible scope under Chimel. The Appellate Division ruled in favor of suppressing the evidence. The New York Court of Appeals reversed the Appellate Division’s order, denying the motion to suppress, thereby upholding the admissibility of the evidence based on their interpretation of Chimel’s applicability.

    Issue(s)

    Whether the ruling in Chimel v. California, which limited the scope of searches incident to arrest, should be applied retroactively to searches conducted after the Chimel decision but before the defendant’s trial.

    Holding

    No, because the Chimel rule applies to searches occurring after June 23, 1969, the date of the Chimel decision, aligning with the Supreme Court’s determination and avoiding inconsistent application within New York State.

    Court’s Reasoning

    The court reasoned that while applying Chimel to trials starting after the decision date might seem more aligned with judicial function, the Supreme Court’s decision in Williams v. United States dictated the approach. The court emphasized the importance of consistency between state and federal application of constitutional rules, stating, “We conclude that there is no sufficiently Compelling reason for us to establish for New York State a time of application different from that recognized by the Supreme Court of the United States.” The court also differentiated this case from People v. Lo Cicero, where both the search and trial were completed before Chimel. The court determined that the Chimel rule did not impact the “very integrity of the fact-finding process” to warrant retroactive application in cases still in the appellate process, referencing People v. Bush and People ex rel. Cadogan v. McMann. Ultimately, the decision prioritizes adherence to established federal precedent to ensure uniform application of constitutional rights.

  • People v. Morales, 22 N.Y.2d 55 (1968): Authority to Detain Suspects for Questioning on Less Than Probable Cause

    22 N.Y.2d 55 (1968)

    Law enforcement officials have the authority to temporarily detain and question suspects on less than probable cause, provided the detention is reasonable in scope and duration, the questioning is conducted under controlled conditions protecting Fifth and Sixth Amendment rights, and the circumstances involve a serious crime affecting public safety.

    Summary

    The New York Court of Appeals addressed whether police can detain a suspect for questioning without probable cause. Morales, suspected in a brutal murder, was picked up and questioned, eventually confessing after being informed of his rights. The court held that temporary detention for questioning is permissible even without probable cause, balancing individual rights with the need for effective law enforcement. This power is limited to situations with serious crimes and is contingent on advising suspects of their rights.

    Facts

    Addie Brown was murdered in her apartment building. Police learned Morales, a known narcotics addict who frequented the building, was present at the time but had not been seen since. After several attempts to locate him, detectives apprehended Morales at his mother’s beauty parlor. He was taken to the police station for questioning, during which he was informed of his right to remain silent and to have an attorney. Morales then confessed to the murder.

    Procedural History

    Morales was convicted of felony murder in the Supreme Court, Bronx County, and sentenced to life imprisonment. The Appellate Division unanimously affirmed the conviction without opinion. Morales appealed, arguing his confession should have been suppressed as the product of an unlawful seizure.

    Issue(s)

    Whether law enforcement officials, lacking probable cause to arrest, may temporarily detain a suspect for questioning without violating the Fourth Amendment’s prohibition against unreasonable seizures.

    Holding

    Yes, because under exceptional circumstances involving a serious crime affecting public safety, a suspect may be detained upon reasonable suspicion for a reasonable and brief period of time for questioning under carefully controlled conditions protecting his Fifth and Sixth Amendment rights.

    Court’s Reasoning

    The Court reasoned that not every detention constitutes an unreasonable seizure under the Fourth Amendment. It balanced the individual’s right to freedom of movement with society’s need to prevent crime. The court acknowledged the lack of clear Supreme Court precedent on this issue. Quoting Justice Frankfurter in Culombe v. Connecticut, the court noted the need for “reconciling the responsibility of the police for ferreting out crime with the right of the criminal defendant, however guilty, to be tried according to constitutional requirements.” The Court emphasized that the detectives informed Morales of his rights prior to questioning. The Court limited its holding to the “exceptional circumstances presented on this appeal involving a serious crime affecting the public safety,” explicitly prohibiting “mass detentions for questioning.” The Court stated, “The scope of the authority to question is limited to those persons reasonably suspected of possessing knowledge of the crime under investigation in circumstances involving crimes presenting a high degree of public concern affecting the public safety.” The Court concluded that, given the brutal nature of the crime, the circumstantial evidence pointing to Morales, and the brief duration of the detention, the police action was reasonable.