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Probable Cause or Reasonable Suspicion: What in the World is the Standard?

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One may not seriously question the assertion that stopping a moving vehicle represents
the most common example of Fourth Amendment implementation. While most believe that the
standard has been relatively static since the Court of Appeals decided People v. Ingle, 36 NY2d
413, 420, 369 NYS2d 67 (1975) and the United States Supreme Court decided Delaware v.
Prouse, 99 SCt. 1391, 59 LEd2d 660 (1979), such is not the case. In Whren v. United States, 517
US 806, 116 SCt 1769, 135 LEd2d 89 (1996), the United States Supreme Court, without
announcing that a substantive change had occurred, mysteriously raised “probable cause” as the
constitutionally mandated level of suspicion necessary to stop an automobile. In People v.
Robinson, 97 NY2d 341, 767 NE2d 638, 741 NYS2d 147 (2001), we again see this apparent
elevation of the standard as the Court of Appeals necessitated “probable cause” for the stop of an
automobile.

As we have noted on previous occasions, (see, 16 NYDWI Bulletin 12, 9 NYDWI
Bulletin 1, 8 NYDWI Bulletin 6, 8 NYDWI Bulletin 18), Whren and Robinson were abundantly
clear in setting forth that the stop of an automobile is valid only when founded upon probable
cause that the motorist has committed or is committing a traffic violation. This is critical
inasmuch as the prior standard, that which was announced in People v. Ingle, supra, clearly
called for reasonable suspicion1. Be there any doubt on that score, it should be noted that the
Ingle court concluded by declaring that “an actual violation of the Vehicle and Traffic Law need
not be detectable” (Ingle at 420). This is not to minimize what the court did in Ingle. When
viewed in the historical perspective of traffic stops in New York, Ingle, as Professor Frank
Anderson pointed out to a bewildered law school freshman 37 years ago, represented a
watershed. For the first time it rendered to antiquity the concept of a “routine check” that had
dominated auto stops in this state.

The issue confronting the Robinson and Whren courts was whether an existing pretextual
basis would invalidate an otherwise valid stop. Holding that it would not, the Court of Appeals
adopted Whren and imposed probable cause of a traffic violation as the basis for the stop of an
automobile in the State of New York. In doing so, Robinson had nothing to say about
“reasonable suspicion” of a crime. Witness the holding:

We hold that where a police officer has probable cause to believe that the driver
of an automobile has committed a traffic violation, a stop does not violate article
I, § 12 of the New York State Constitution. In making that determination of
probable cause, neither the primary motivation of the officer nor a determination
of what a reasonable traffic officer would have done under the circumstances is
relevant.

Robinson, at 349.

Despite the foregoing, it may be safely said that what has emerged in practice is a dual
standard. That standard requires probable cause to stop for a traffic violation or reasonable
suspicion that the motorist has committed or is committing a crime. In 2006, for instance, the
Fourth Department decided People v. White, 27 AD3d 1181, 812 NYS2d 208 which declared;

The police may lawfully stop a vehicle when they have “probable
cause to believe that the driver of [a vehicle] has committed a
traffic violation” (People v. Robinson, 97 NY2d 341, 349, 741
NYS2d 147, 767 NE2d 638; see People v. Washburn, 309 AD2d
1270, 1271, 765 NYS2d 76), and they may lawfully stop a vehicle
when there exists at least a reasonable suspicion that the driver
or occupants of the vehicle have committed, are committing, or are
about to commit a crime” (People v. Spencer, 84 NY2d 749, 753,
622 NYS2d 483, 646 NE2d 785, cert. denied 516 US 905, 116 SCt
271, 133 LEd2d 192).27 AD3d 1181, 812 NYS2d 208 (4th Dept.
2006).

White, supra., [emphasis supplied herein].

Returning to this theme, in 2009 the Fourth Department decided what is perhaps the clearest
declaration of the shift, recognized the abrogation of Ingle and neatly denominated the new rule:

In support of their contention that the stop was valid, the People mistakenly rely
on People v. Ingle, 36 NY2d 413, 369 NYS2d 67, 330 NE2d 39, in which the
Court of Appeals held that the stop of a vehicle is lawful provided that it is “not
the product of mere whim, caprice, or idle curiosity . . . [and is] based upon
‘specific and articulable facts’ ” (id. at 420, 369 NYS2d 67, 330 NE2d 39, quoting
Terry v. Ohio, 392 US 1, 21, 88 S.Ct. 1868, 20 LEd2d 889). As defendant
correctly contends, however, in the time since Ingle “the Court of Appeals has
made it ‘abundantly clear’ . . . that ‘police stops of automobiles in this State are
legal only pursuant to routine, nonpretextual traffic checks to enforce traffic
regulations or where there exists at least a reasonable suspicion that the driver or
occupants of the vehicle have committed, are committing, or are about to commit
a crime’ . . . or where the police have ‘probable cause to believe that the driver . .
. has committed a traffic violation’ (People v. Washburn, 309 AD2d 1270, 1271,
765 NYS2d 76; see People v. Robinson, 97 NY2d 341, 348-349, 741 NYS2d 147,
767 NE2d 638; People v. Spencer, 84 NY2d 749, 752-753, 622 NYS2d 483, 646
NE2d 785,cert. denied 791516 US 905, 116 SCt 271, 133 LEd2d 192; People v.
White, 27 AD3d 1181, 812 NYS2d 208).

People v. Rose, 67 AD3d 1447, 1448, 889 NYS2d 789, 790 [4th Dept. 2009]) [emphasis supplied
herein].

Recognizing that the Fourth Amendment interest to be protected is singular in nature, we
must now ask from where did this dual standard spring? The answer to this question seems to
be People v. Spencer, 84 NY2d 749, 753, 622 NYS2d 483, 646 NE2d 785 [1995], cert. denied
516 US 905, 116 SCt 271, 133 LEd2d 192 [1995].

Spencer is an interesting case, although factually one can read the opinion and question
how it got as far as it did. In Spencer, the police were seeking the perpetrator of an assault with a
weapon. Driving around some 43 hours after the assault, they happened to spot what the victim
described as the vehicle of the suspect’s friend double parked2 with the friend in the driver’s seat.
Upon spotting the police cruiser, the parked vehicle began to move. At this point, the police
activated their turret and what the decision described as the horn. This caused the vehicle to stop
and the officers thereafter approached. Upon approach, they observed what the decision
described as a “green vegetable like substance” that proved to be marijuana. Following the
removal of the defendant from the vehicle, they observed the butt of a gun under the seat. The
gun proved to be loaded and the defendant was subsequently charged with Criminal Possession
of a Weapon in the Third Degree and Criminal Possession of Marihuana in the Fourth Degree.

The defendant’s motion to suppress was denied by the trial court, which denial was
affirmed by the Appellate Division (193 AD2d 90, 602 NYS2d 412 [1993]).

At issue was whether the stop of the defendant’s vehicle for “informational” purposes
was valid. The Court of Appeals held that it was not. While the court found that a police officer
can always stop a citizen who is on foot to request information, it acknowledged that the same
will not hold true for a motorist in a vehicle. Citing the significant differences that exist between
the informational stop of an individual on the street (see, People v. Holmes. 81 NY2d 1056, 601
NYS2d 459 [1993]) and the stop of an automobile, the Court reaffirmed People v. May (81
NY2d 725, supra), where it held that “the police officers’ premise for that order – the commonlaw
right of inquiry – did not satisfy Fourth Amendment standards: “the stop was proper only if
the officers had a reasonable suspicion of criminal activity” (id., at 727).” Finding the stop
invalid, the court once again drove home the standard that had controlled the area of automobile
stops since Ingle:

[T]he Fourth Amendment requires that a seizure must be based on specific,
objective facts indicating that society’s legitimate interests require the seizure of
the particular individual, or that the seizure must be carried out pursuant to a plan
embodying explicit, neutral limitations on the conduct of individual officers”
(Brown v Texas, 443 US 47, 51; see, People v. Scott, 63 NY2d 518, at 525). We
need not and do not hold today that police officers may never stop a vehicle in
order to request information of its occupants. We merely hold that the specific,
objective facts of this case did not justify defendant’s seizure.

However, Spencer said more. Much more. In laying the constitutional basis for the stop of a
motor vehicle, Spencer recognized the requisite Fourth Amendment imperative:

We have stated, time and again, that the stop of an automobile is a seizure
implicating constitutional limitations (People v. May, 81 NY2d 725; Sobotker, 43
NY2d 559,supra; Ingle, 36 NY2d 413, supra; see, Delaware v. Prouse, 440 US
648, 653 [“stopping an automobile and detaining its occupants constitute a
‘seizure’ within the meaning of (the Fourth Amendment), even though the purpose
of the stop is limited and the resulting detention quite brief”]).

Spencer at 752.

Since Ingle and Prouse supplied the standard that the court subsequently applied, we
must now ask, “What was the standard?” The answer to that question is that in 1995
the standard which was uniformly applied in analyzing the constitutionality of all traffic stops
was reasonable suspicion (see, People v. Ingle, supra. [“specific and articulable facts which,
taken together with rational inferences from those facts, reasonably warrant [the] intrusion”
(citing Terry v. Ohio, 392 U.S. 1)] and see, Delaware v. Prouse, supra., [“articulable and
reasonable suspicion that a motorist is unlicensed or that an automobile is not registered, or that
either the vehicle or an occupant is otherwise subject to seizure for violation of law”]).

As we said, Spencer said much more. In what was perceived by some to be a
condemnation of so-called pretextual stops, the court declared:

[P]olice stops of automobiles in this State are legal only pursuant to routine,
nonpretextual traffic checks to enforce traffic regulations or when there exists at
least a reasonable suspicion that the driver or occupants of the vehicle have
committed, are committing, or are about to commit a crime[.]

Spencer at 753, citations omitted.

Use of the term “non-pretextual” would lead many to believe that New York was
rejecting otherwise valid traffic stops that were executed for pretextual reasons which were
otherwise not supported by probable cause. Therefore, adoption of the Whren standard in
Robinson, required the court to sweep aside a major impediment which was apparently created by
Spencer. The court did so when it defended interjection of the term “non-pretextual” by
explaining that it was merely eschewing the use of an unstandardized discretionary standard:

We noted that “police stops of automobiles in this State are legal only pursuant to
routine, nonpretextual traffic checks to enforce traffic regulations or when there
exists at least a reasonable suspicion that the driver or occupants of the vehicle
have committed, are committing, or are about to commit a crime” (id., at 753).
However, we explained what we meant by pretextual when we further noted that
“there were no objective safeguards circumscribing the exercise of police
discretion” and that if such stops “were permissible and motorists could in fact be
pulled over at an individual police officer’s discretion based upon the mere right to
request information, a pandora’s box of pretextual police stops would be opened”
(id., at 758, 759). Central to Spencer‘s holding was the absence of an objective
standard for stopping a vehicle. Thus, a police officer could contrive a reason to
stop a vehicle merely to make an inquiry. However, an objective standard is
present here–the Vehicle and Traffic Law.

Robinson at 351.

Lost in the shuffle is that the reasonable suspicion which was referred to in the foregoing
paragraph was in serious jeopardy as a result of the very case which the court was in the process
of adopting, Whren v. United States, 517 US 806, 116 SCt 1769, 135 LEd2d 89 [1996].3 While
Ingle, supra., and Prouse, supra., had adopted a reasonable suspicion standard for the stop of a
motor vehicle, that standard was succinctly and completely turned aside by the Court in Whren:

An automobile stop is thus subject to the constitutional imperative that it not be
“unreasonable” under the circumstances. As a general matter, the decision to stop
an automobile is reasonable where the police have probable cause to believe that
a traffic violation has occurred.

Whren, at 810 [emphasis supplied herein]; compare, Delaware v. Prouse, at 663.

The question that remains is does “reasonable suspicion,” which was clearly valid when
Spencer was decided, still apply when there is “reasonable suspicion that the driver or occupants
of the vehicle have committed, are committing, or are about to commit a crime?”

The answer to this question calls for an examination of how the reasonable suspicion
standard came to be. The first clause of the Fourth Amendment to the United States Constitution
inveighs against “unreasonable” searches and seizures. This term gains definition in the second
clause of the Fourth Amendment which bars the issuance of warrants founded upon less than
probable cause. Prior to the landmark decision of the Court in Terry v. Ohio, 392 US 1, 16, 88
SCt 1868, 1877, 20 LEd2d 889 [1968], there existed a constitutional no man’s land between a
full blown search founded upon probable cause, as that term came to be defined, and those
without “probable cause’ but which could objectively be classified as reasonable (see, People v.
Rivera, 14 NY2d 441, 252 NYS2d 458, 201 NE2d 32 [1964], cert. denied, 379 US 978, 85 SCt
679, 13 LEd2d 568 (1965), People v. Taggart, 20 NY2d 335, 342, 283 NYS2d 1, 8, 229 NE2d
581, 586, [1967]; People v. Pugach, 15 NY2d 65, 255 NYS2d 833, 204 NE2d 176 (1964), cert.
denied, 380 US 936, 85 SCt 946, 13 LEd2d 823 [1965] [cited by Terry at FN 15]). With the
decision in Terry, the Warren Court, in one of Earl Warren’s last decisions, found itself
positioned squarely between the Fourth Amendment and an ever increasing demand for law and
order. In an environment that included vengeful fire from the ideological rifts laid bare by the
1968 presidential campaign as well as the knowledge of his own impending resignation,4 Warren
confronted one of the most volatile issues of the day, the safety of a police officer. The result
was an anguished, heartfelt yet brutally consistent attempt to balance the Fourth Amendment
against very real concerns for the safety of police officers. Rejecting the assertion that the act of
frisking Terry did not constitute a search so as to be fully excluded by the Fourth Amendment,
Warren took great pains to isolate the constitutionally legitimate procedure to which he was
lending the Court’s imprinteur from the judicially created remedy of the exclusionary rule.
Without referencing the term “reasonable suspicion” (in Terry it appeared solely in Justice
White’s concurrence) Warren coupled a well-founded and articulable suspicion that criminal
activity was at hand with an immediate concern for officer safety. Importantly, this diminution in
the threshold required for a seizure carried with it a concomitant limitation in the scope of the
examination that would be permitted.

In reaching this point, Warren early on set out the crucial and often overlooked difference
between the first and second clauses of the Fourth Amendment. The first clause protects the
right of persons to be secure in their persons, houses, papers and effects against unreasonable
searches and seizures. Unlike the second clause, it does not mandate the presence of “probable
cause” to establish the reasonableness of the conduct. The use of “reasonable” and the absence
of a requirement for “probable cause” in the opening clause would prove dispositive. As
explained by the court:

If this case involved police conduct subject to the Warrant Clause of the Fourth
Amendment, we would have to ascertain whether ‘probable cause’ existed to
justify the search and seizure which took place. However, that is not the case. * *
* [W]e deal here with an entire rubric of police conduct – necessarily swift action
predicated upon the on-the-spot observations of the officer on the beat – which
historically has not been, and as a practical matter could not be, subjected to the
warrant procedure. Instead, the conduct involved in this case must be tested by the
Fourth Amendment’s general proscription against unreasonable searches and
seizures.

Terry, at 20 [footnote omitted].

In sum, a so-called Terry stop-frisk may be seen as the rare instance when the term
“unreasonable” does not denote “probable cause.”

Since the decision in Terry, reasonable suspicion, as a basis for seizure, has seen
relatively limited expansion. Most notable areas of inclusion are the stop of a motor vehicle
(Ingle, supra.; Prouse, supra.) and transportation to a show up identification (see, People v.
Hicks, 68 NY2d 234, 508 NYS2d 163, 500 NE2d 861 [1986]). So far as we can discern, with the
exception of these arguably Terry type situations, reasonable suspicion has seen no further
expansion.

Whren however, changed the landscape. While one may argue that the use by the High
Court of the term “probable cause” where one would ordinarily have expected the court to use
the term “reasonable suspicion” was merely a slip of the judicial pen, much as Judge Ciparik’s
infamous “greater then .10 percent” in Pringle v. Wolf (88 NY2d 426, 429, 646 NYS2d 82, 84,
668 NE2d 1376 [1996], cert. denied 519 US 1009, 117 SCt 513, 136 LEd2d 402 [1996]), an
analysis of subsequent cases will not bear it out. As clearly set out in a litany of decisions which
have followed (Ohio v. Robinette, 519 US 33, 117 SCt 417 136 LEd2d 347 [1996]; City of
Indianapolis v. Edmonds, 531 US 32, 121 SCt 447, 148 LEd2d 333, 69 USLW 4009 [2000];
Atwater v. City of Lago Vista, 532 US —, 121 SCt 1536, 149 LEd2d 549 [2001] (dissent per
O’Connor, Stevens, Ginsburg, and Justice Breyer)], the standard is most decidedly probable
cause which, as a 5 matter of Federal Law, is binding upon the states.

Whren and Robinson, standing on their own, should have ended the matter. Making no
provision for reasonable suspicion, a single standard should have been imposed to regulate the
stop of a motor vehicle. Such however, has not been the case. Virtually every term there has
emerged a decision wherein an Appellate Division makes reference to a dual reasonable
suspicion/probable cause standard (see, People v. Houghtalen, 89 AD3d 1163, 931 NYS2d 922
[3rd Dept., 2011]; People v. Cash J.Y, 60 AD3d 1487, 876 NYS2d 289 [4th Dept., 2009]; People
v. Stock, 57 AD3d 1424; 871 NYS2d 545 [4th Dept., 2008]; People v. Rose, supra.; People v.
Phillips, 46 AD3d 1021, 847 NYS2d 688 [3d Dept, 2007]; People v. Long, 36 AD3d 132, 824
NYS2d 249 [1st Dept., 2006]).

What all these cases have in common is citation to People v. Spencer, supra. Spencer, of
course, did not emerge from a vacuum. Spencer’s reliance upon reasonable suspicion finds its
basis in People v. Sobotker, 43 NY2d 559, 402 N.Y.S.2d 993 [1978] which in turn, implemented
the recently coined rule of Ingle. Likewise, it turned to Judge Wachtler’s 1982 ruling in People
v. Harrison, 57 NY2d 470, 457 N.Y.S.2d 199, which applied Ingle as it voided a stop based upon
the excessively dirty nature of a vehicle.

Typical of this reliance upon Spencer, and to a lesser degree, Sobotker and Harrison, to
support reasonable suspicion is the recent decision of the Third Department in People v.
Houghtalen, 89 AD3d 1163, 931 NYS2d 922 (3rd Dept., 2011). In Houghtalen, police were
seeking the perpetrator of a purported domestic assault. They eventually encountered a vehicle
driven by the defendant in which the perpetrator was believed to be riding. Following a stop of
the vehicle, the officers noted that the operator displayed the classic indicia of intoxication.
Following the failure of a field sobriety test, the defendant was placed under arrest.

At the trial level, the defendant contested the stop of his vehicle and after the stop was
upheld, he pled guilty to Driving While Intoxicated as a Felony while specifically reserving the
right to contest the basis for the stop. On appeal, the Third Department affirmed. In doing so,
and with citation to Spencer it observed that:

A traffic stop by police is lawful “when there exists at least a reasonable suspicion
that the driver or occupants of the vehicle have committed, are committing, or are
about to commit a crime.

As though to further illustrate the poisonous tree from which the fruit of reasonable suspicion is
being plucked, the Houghtalen court cited People v. Brisson, 68 AD3d 1544, 892 NYS.2d 618
[2009]. Brisson, in upholding a finding of reasonable suspicion, relied upon none other than
Sobotker. Likewise, the Houghtalen court cites People v. Booker, 64 AD3d 899, 900, 881
NYS2d 735, as authority for reasonable suspicion. Although Booker, decided in 2009, post dates
Robinson and Whren by eight years and thirteen years respectively, it nevertheless cites as its
authority Sobotker. Additionally, the circular nature which permeates the reasonable suspicion
line of reasoning can be seen in citation by the Booker court of Spencer.

The sum of all this is simple. Ingle, Sobotker and reasonable suspicion as the basis for
the stop of an automobile are dead. With the decisions in Whren and Robinson reasonable
suspicion was returned to the realm of officer safety and the Terry stop where, looking back, it
seems that a tired and beleaguered Earl Warren intended for it to stay all along.

Notes

1.While some may argue that the Ingle court used the terms “probable cause” and “reasonable
suspicion” analogously (see, Ingle at p. 20) such is not the case. In fact, while commenting
favorably about the position taken by California and Pennsylvania in 1975, the Ingle court took
great pains to indicate that the level imposed in both instances was reasonable suspicion [“The
position there taken, however, took the form of requiring as a basis for a “routine” traffic stop
what was characterized as probable cause, but which may be no different than the reasonable
suspicion suggested earlier as the basis for a “routine” traffic stop what was characterized as
probable cause” (Ingle, at 20, emphasis supplied herein). Further evidence of the futility of this
position can be seen in the fact that in discussing these jurisdictions, the court, with citation to
Terry made specific reference to balancing [“The analogies are many and provide, in the case of
pedestrian stops and in at least one instance of a vehicle statute, dramatic demonstration of the
balancing of competing interests presented by the need for legitimate and effective law
enforcement, and the control of intrusions on personal freedom of movement ” (Ingle, supra.].
Additionally, such an assertion is inherently inconsistent with the example given by the court as
to the manner in which the new rule should be applied [“It should be emphasized that the factual
basis required to support a stop for a ‘routine traffic check’ is minimal. An actual violation of the
Vehicle and Traffic Law need not be detectable. For example, an automobile in a general state of
dilapidation might properly arouse suspicion of equipment violations. All that is required is that
the stop be not the product of mere whim, caprice, or idle curiosity (Ingle, supra.)]. Finally, this
position is not borne out by later cases such as Sobotker and Harrison (infra.).

2.Oddly, the fact that the vehicle was double parked played no role in the resolution.

3.In fairness to the Robinson court, it appears that this passage was quoted solely to limit the
court’s earlier use of the term “nonpretextual”. It does not appear that the balance was in any
manner intended to somehow become the holding of that case. Indeed, this point seems clear in
that, as discussed below, Spencer and not Robinson continues to be cited for the proposition that
reasonable suspicion and not probable cause is the standard for a stop when criminal activity is
suspected.

4.Warren submitted two “contingent” letters of resignation to President Johnson on June 13th,
1968, just three days after Terry was announced.

5.But why would the Court in Whren quietly change the half century old standard? As we noted
back in 2001 (see, 8 NYDWI Bulletin 6) and giving the Court the benefit of the doubt, there may
be a reason. In Whren, the Court was faced with a difficult and problematic decision; whether
pretextual automobile stops would be permitted. Remember that when Carroll v United States
was decided, an automobile was an infinitely more elusive creature than it is today. The
Motorola police radio was thirty years off and the mobile data terminal was comic book fantasy.

Data basing of items such as warrants and the like was a virtual and practical impossibility.
Once a 1927 Ford got away, as Clyde Barrow proved on all but one occasion, it may never be
found. Not so today. It is truly difficult for a motorist to escape prosecution. With the onset of
checkpoints, much of the rationale underlying Carroll ceased to have any real meaning. Couple
this with a ruling that says a burned out tail lamp may be utilized as a sufficient basis to stop a
“known” drug dealer, and some additional level of Fourth Amendment protection seems to be
required. Indeed, a close reading of Justice Ginsberg’s recent dissent in Arkansas v Sullivan, 532
US 769, 121 SCt 1876 [2001], seems to bear out this concern. It appears, to our eye at least, that
the Court may have quietly determined that the “additional level” of protection is “probable
cause.” In short, Whren, by abolishing “reasonable suspicion” as a basis for a stop, may have
given back more than anyone originally thought.

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