People v. Yancy

In People v. Yancy, 86 N.Y.2d 239 (1995), the Court of Appeals upheld the search of a validly stopped automobile where the police officers observed a bag of empty plastic vials in the back seat of the car. The Court noted that: " while an officer's inadvertent or incidental observation of an openly visible article that is known to have illicit uses is in and of itself insufficient to establish probable cause to justify a warrantless automobile search (cites omitted), we have recognized that the presence of 'additional relevant behavior or circumstances' can give rise to probable cause and justify the warrantless search and seizure." (Id. at 246.)