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

In People v. Watts, 43 AD3d 256, 840 N.Y.S.2d 69 (1st Dep't 2007), lv. den., 9 N.Y.3d 965, 878 N.E.2d 618, 848 N.Y.S.2d 34, the police, in response to an anonymous 911 call concerning a mailbox being taken by two men approached two men who matched the description of the caller.

The men had what appeared to be sheetrock dust and plaster on their pants and shoes. When the two men could not produce identification, and indicated they were coming from the area where the 911 call had indicated the crime was committed, the police performed a protective frisk of the defendants.

In upholding the legality of the search, the First Department held that "[w]hen a police officer confronts an individual whom he reasonably suspects has committed an inherently dangerous crime such as burglary, that suspicion alone justifies not only detention but also a frisk for weapons." People v. Watts, supra, at 258.