People v. Singletary, 37 N.Y.2d 311 (1975)

A search of a student by a school official is permissible under the Fourth Amendment if based on concrete, articulable facts provided by a reliable informant, even if the informant’s identity is not disclosed.

Summary

Singletary was adjudicated a youthful offender after a search by a high school dean revealed heroin. The search was prompted by a student informant who had previously provided accurate information leading to drug-related arrests and convictions. Singletary argued the search violated his Fourth Amendment rights under the precedent of People v. Scott D. and that he should have been able to elicit the informant’s identity at the suppression hearing. The New York Court of Appeals affirmed the adjudication, distinguishing Scott D. based on the reliability of the informant and emphasizing that an in camera examination of the informant adequately protects the defendant’s rights.

Facts

A high school dean responsible for security was approached by a student informant who stated Singletary possessed and was selling narcotics on school property.
The informant had provided similar information on five prior occasions, each leading to the seizure of narcotics.
The students named by the informant in those prior instances were subsequently arrested and convicted of drug-related charges.
The dean searched Singletary and found 13 glassine envelopes containing heroin in his sock.

Procedural History

Singletary was adjudicated a youthful offender in the Criminal Court of the City of New York based on a guilty plea to attempted possession of a narcotic drug.
Appellate Term affirmed the judgment.
Singletary appealed to the New York Court of Appeals by leave of a judge.

Issue(s)

Whether the search of Singletary by the school dean violated his Fourth Amendment rights, considering the information was provided by a student informant.
Whether Singletary was entitled to elicit the identity of the student informant at the suppression hearing.

Holding

No, because the dean acted on concrete, articulable facts supplied by an informant whose reliability had been proven by the accuracy of previous communications.
No, because the defendant’s rights are adequately protected by an in camera examination of the informant by the hearing judge.

Court’s Reasoning

The court distinguished this case from People v. Scott D., where the information was imprecise and the informant’s reliability was not established. In Singletary’s case, the informant had a proven track record of providing accurate information leading to arrests and convictions.

The court relied on People v. Darden and People v. Goggins, which held that a defendant is not necessarily entitled to learn the identity of an informant at a probable cause hearing, especially when probable cause rests solely on the informant’s information. The court stated that when probable cause is the issue, as opposed to guilt, the defendant’s rights are amply protected by an in camera examination of the informant by the hearing Judge. The court noted that no in camera examination was requested in this case.

“The rule enunciated by Chief Judge Breitel in Scott D. was designed to prevent teachers or other school officials from exercising ‘arbitrary power’ by engaging in ‘random causeless searches’ based upon unfounded ‘equivocal suspicion’.” The court found that the search in this case was not arbitrary but based on reasonable suspicion supported by a reliable informant.