## Facts

- New York City police officers on night patrol in the Bronx, assigned to a street-crime unit focused on taxi safety, observed a vehicle speed through a red light.
- The officers stopped the vehicle using high-intensity lights; they believed it was a livery cab.
- After the stop, an officer shined a flashlight into the back seat and observed passenger Frank Robinson wearing a bulletproof vest.
- The officer ordered Robinson out of the vehicle and then saw a gun on the floor where Robinson had been seated.
- Robinson was arrested and charged with criminal possession of a weapon and unlawfully wearing a bulletproof vest.
- Robinson moved to suppress the gun and vest, arguing the traffic stop was a pretext to investigate him rather than to enforce traffic laws.
- The trial court denied suppression; Robinson was convicted and sentenced as a persistent violent felony offender.
- The Appellate Division affirmed; the New York Court of Appeals granted leave and addressed whether the state constitution bars pretextual traffic stops.

## Issues

1. Whether article I, § 12 of the New York Constitution invalidates a traffic stop supported by probable cause when the officer’s primary motive is to pursue a non-traffic criminal investigation.
2. Whether evidence discovered after such a stop must be suppressed as the product of an unconstitutional seizure.

## Decision

- The New York Court of Appeals affirmed the denial of suppression and Robinson’s conviction.
- The court held that a stop is lawful under article I, § 12 when police have probable cause to believe a traffic infraction occurred, regardless of the officer’s subjective motivation.
- The court adopted *Whren v. United States* as a matter of state law for evaluating allegedly pretextual traffic stops.
- Applying that rule, the observed red-light violation supplied probable cause for the stop; the officers’ stated lack of intent to issue a summons did not invalidate it.
- Because the initial stop was lawful, the subsequent observations of the vest and the gun provided a lawful basis for further detention and arrest, and suppression was unwarranted.

## Legal Principles

- Under N.Y. Const. art. I, § 12, a vehicle stop is constitutionally valid when supported by probable cause that a traffic law was violated.
- The validity of a traffic stop does not depend on an officer’s subjective or primary motivation; the test is objective.
- Courts will not require suppression solely because a traffic stop was used to facilitate another investigation, absent an independent constitutional violation (e.g., discriminatory enforcement addressed through equal protection principles).
- Items observed from a lawful vantage point during a lawful stop may supply grounds for further detention and seizure.

## Conclusion

The court held that a traffic stop supported by probable cause is reasonable under the New York Constitution even if used as a pretext for other investigative aims, and it upheld the admission of the gun and bulletproof vest discovered after the lawful stop.


People v. Robinson, 767 N.E.2d 638 (N.Y. 2001)