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People v. Samuel – Case Brief Summary (New York)

In People v. Samuel, 29 NY2d 252, 257, 277 N.E.2d 381, 327 N.Y.S.2d 321 (1971), the Court of Appeals upheld as constitutional the Vehicle and Traffic Law provision that requires a driver involved in an accident to remain at the scene, identify him or herself, and report the accident to the police.

The Court held that such a reporting requirement did not violate an individual's privilege against self-incrimination In reaching this conclusion, the Court relied upon the fact that the purpose of the statute at issue was not to incriminate (the reporting requirement had an "incidental and limited risk of inculpation"), but rather, its purpose was to regulate a lawful activity to protect the public from significant harm. (Id. at 262.)