People v. Prochilo, 41 N.Y.2d 247 (1976)

Whether reasonable cause exists to conduct a warrantless search and seizure is a factual determination beyond the scope of appellate review unless the determination is erroneous as a matter of law.

Summary

This case concerns the legality of a warrantless search based on information from informants and police corroboration. The Court of Appeals affirmed the lower court’s decision, holding that the search was justified by reasonable cause. The court emphasized that determinations of reasonable cause are factual and generally beyond appellate review unless an error of law is evident. The ruling underscores the importance of informant reliability, police corroboration, and the scope of the search in assessing the validity of a warrantless search.

Facts

Undercover police officers received information from two informants that the defendant, a bartender, was storing cocaine in the kitchen refrigerator of the bar where he worked. The informants also indicated the defendant had sold the drug to a patron. Based on this information, the officers visually observed the defendant. The officers then searched the refrigerator in the defendant’s presence without informing him of his constitutional rights or arresting him until after the search. The search revealed cocaine.

Procedural History

The defendant sought to suppress the evidence obtained during the search. The lower court denied the motion to suppress. The Appellate Division affirmed that decision. The case then went to the New York Court of Appeals.

Issue(s)

1. Whether the warrantless search of the refrigerator was supported by reasonable cause.
2. Whether the testimony of the police officers was so inconsistent as to be deemed incredible as a matter of law.

Holding

1. Yes, because the information provided by the informants was corroborated by the officers’ visual observations, giving rise to reasonable cause for the search.
2. No, because the alleged discrepancies in the officers’ testimony were insignificant and did not undermine the fundamental factual issues.

Court’s Reasoning

The Court of Appeals emphasized that the determination of reasonable cause for a warrantless search is a factual one, and the court’s power of review is limited unless an error of law is evident. The court found no such error, noting that the officers’ testimony, based on information from informants and corroborated by their own observations, provided a sufficient basis for the lower courts to find that the search was justified. The court quoted People v. Clements, 37 NY2d 675, 680, stating that the search was not a “wide-ranging, exploratory, rummaging, or routine search of the character condemned in Chimel v. California“. The court rejected the argument that the officers’ testimony was incredible, stating that credibility is a factual issue generally outside the scope of their review. The court reasoned that the alleged inconsistencies in the officers’ testimony were insignificant. As stated in People v Alexander, 37 NY2d 202, 204, credibility is a factual issue which is not generally within the competence of appellate review.