People v. Ingle Case Brief

Summary of People v. Ingle
36 NY2d 413(1975)

Facts: The accused, Roger Ingle, was pulled over in his car and found to be in possession of marijuana. His car was pulled over because of its unusual, but irrelevant appearance. The automobile appeared unusual due to its antiquity and condition. The officer asked then conducted a normal inspection of the car. Upon inspection of the car, the officer noticed the scent of marijuana and searched the car. The search revealed a marijuana pipe, a smoked joint and a bag containing marijuana. The defendant was then arrested and charged with possession of a dangerous substance.

Procedural History: The argument of the defense was that the arresting officer’s search and seizure of the automobile was not justified in that he did not have reasonable suspicion to first stop the vehicle and second search the vehicle. Prosecution argued that the officer was within his power and that police reserved the right to practice routine pullovers. The defendant was found guilty and the decision was upheld upon initial appeal to the Appellate Division. A second appeal was then granted to the New York Court of Appeals.

Issue: Was the stop without reasonable suspicion exceeding the police officer’s power to detain?

Holding: The decision of the Appellate Division was overturned and the charges against the defendant were subsequently dismissed.

Rationale: The New York Court of Appeals held that police do not reserve the right to make random traffic stops without at least reasonable suspicion to do so. Therefore the evidence that was found during the search of the vehicle was ruled inadmissible as evidence.

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