## Facts

- A patrol officer stopped Melvin Adams’s car late at night for driving with high-beam headlights.
- The officer checked Adams’s license and registration and compared the vehicle identification number (VIN) to reference materials.
- The VIN on the vehicle and registration did not match the vehicle description in the reference materials.
- The officer arrested Adams for violating New York Vehicle and Traffic Law § 422 (possession of a motor vehicle with a defaced/altered identification number without proper application).
- Immediately after arrest, the officer conducted a full search of Adams’s person that went beyond a protective pat-down and included searching pockets.
- The officer found marijuana in Adams’s coat pocket.
- A subsequent search of the car produced additional marijuana, a scale, and manila envelopes.
- Adams was charged with marijuana possession and a motor vehicle identification offense; the trial court denied suppression, and the intermediate appellate court affirmed.

## Issues

1. Whether a full search of an arrestee’s person is constitutionally reasonable as a search incident to arrest when the arrest is for a minor Vehicle and Traffic Law offense under § 422.
2. Whether the scope of the officer’s search exceeded what was justified by officer safety or the likelihood of finding evidence related to the offense of arrest.
3. Whether evidence recovered from the vehicle search was inadmissible as derivative of an unconstitutional search of the person.

## Decision

- The New York Court of Appeals reversed and held the search unconstitutional.
- The court concluded the arrest and initial encounter could be reasonable, but the search was unreasonable in scope.
- The court held that a § 422 violation, without additional circumstances, did not justify a full search of Adams’s person beyond a weapons frisk.
- The marijuana found on Adams’s person was suppressed, and the items found in the car were also inadmissible as fruits of the unlawful search.

## Legal Principles

- The Fourth Amendment analysis turns on reasonableness; a lawful arrest does not automatically authorize any search without limit.
- A search incident to arrest must be justified by legitimate objectives such as officer safety (weapons) or preservation/discovery of evidence related to the offense of arrest.
- For a minor Vehicle and Traffic Law offense, a full search of the person is not justified absent reasonable grounds to believe it is needed for officer safety or will produce evidence related to that offense.
- Evidence obtained through an unconstitutional search, and evidence derived from it, is inadmissible under exclusionary principles.

## Conclusion

The court held that, although the stop and arrest for a § 422 violation could be valid, the officer’s full pocket search was not justified by the nature of the offense or the circumstances, requiring suppression of the marijuana and the derivative evidence found in the vehicle.


People v. Adams, 32 N.Y.2d 451 (N.Y. 1973)