People v. Santiago

In People v. Santiago, 168 Misc 2d 883 [1996] defendant was observed driving a motor vehicle on a public highway, stopped by police and upon a check with the DMV he was arrested after the DMV abstract showed nine license suspensions on three different dates without the license having been reinstated. The court in suppressing the DMV abstract held that the preexisting DMV records are suppressible as "fruit of the poisonous tree" and that suppression "applies ... to evidence which flows from illegal seizures, such as verbal statements, identifications, and testimony at trial as to matters observed during or resulting from the unlawful seizure." (Santiago, supra at 886.)