## Facts

- The New York Court of Appeals consolidated three criminal cases challenging vehicle stops as “pretextual” under N.Y. Const. art. I, § 12.
- In Robinson, Street Crime Unit officers in the Bronx saw a vehicle proceed through a red light and stopped it, stating they did not intend to issue a summons.
- While approaching, an officer illuminated the rear seat area and saw the defendant wearing a bulletproof vest; after removing him, the officer observed a gun on the floor where he had been seated.
- Robinson was charged with weapon possession and unlawfully wearing a bulletproof vest; he moved to suppress the gun and vest as fruits of a pretextual stop. The motion was denied and his conviction was affirmed below.
- In Reynolds, an officer followed a truck after observing a known prostitute enter it; a computer check showed the registration had expired, and the officer stopped the vehicle.
- During the Reynolds stop, the officer observed signs of intoxication, administered field sobriety tests, and arrested the driver for DWI and operating an unregistered vehicle; the defendant sought suppression as pretextual.
- In Glenn, officers saw a taxi fail to signal and suspected possible robbery activity based on a passenger’s movements; they stopped the taxi for the signaling infraction and discovered narcotics, leading to drug charges.
- The lower courts had reached different results on whether a stop supported by a traffic violation becomes unlawful if the officer’s primary purpose is investigating unrelated crime.

## Issues

1. Whether, under N.Y. Const. art. I, § 12, a traffic stop supported by probable cause (or reasonable cause) of a traffic infraction is unconstitutional if the officer’s primary motivation is to investigate unrelated criminal activity.
2. Whether evidence discovered after such a stop must be suppressed on the theory that the stop was “pretextual.”
3. Whether concerns about discriminatory enforcement require a search-and-seizure rule turning on an officer’s subjective intent.

## Decision

- The Court of Appeals held that a vehicle stop is lawful whenever police have probable cause to believe a traffic violation occurred, regardless of the officer’s ulterior or primary investigative motive.
- The court adopted Whren v. United States as a matter of state constitutional law for traffic stops.
- The court rejected a suppression rule requiring courts to examine an officer’s subjective intent to determine whether a stop was “pretextual.”
- Applying the objective rule, the court upheld the stops and denied suppression challenges in Robinson, Reynolds, and Glenn because each stop was supported by a traffic-law basis (red-light violation, expired registration, and failure to signal).

## Legal Principles

- Under N.Y. Const. art. I, § 12, the legality of a traffic stop turns on objective justification (probable cause or reasonable cause of a traffic infraction), not the officer’s subjective motivation.
- Evidence is not suppressible merely because a defendant claims the traffic stop was used to pursue a different criminal investigation.
- Claims that traffic enforcement is applied in a discriminatory manner are addressed through equal-protection and selective-enforcement doctrines rather than a search-and-seizure rule invalidating stops based on alleged pretext.
- An objective standard is favored to avoid litigation over an officer’s state of mind and to provide predictable suppression rules.

## Conclusion

The New York Court of Appeals aligned state search-and-seizure law for traffic stops with the federal Whren rule, holding that a stop supported by probable cause of a traffic violation is valid even if officers acted to investigate unrelated criminal activity, leaving discrimination-based challenges to equal-protection remedies rather than automatic suppression.


People v. Robinson, 97 N.Y.2d 341 (N.Y. 2001)