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Matter of Muhammad F – Case Brief Summary (New York)

In Matter of Muhammad F., 94 N.Y.2d 136 [1999] police officers assigned to a taxi-livery task force conducted roving patrols in unmarked police cars. The officers selected locations involving a high incidence of robberies against taxicabs and, in the absence of probable cause or any suspicious behavior, pulled over a predetermined percentage of livery cabs for the purpose of conducting safety checks. The checks involved a brief conversation with the driver after which any passengers were requested to exit the vehicle. Officers then conducted searches around and under the seats. The stops generally occurred between the hours of 6:00 P.M. and 2:00 A.M.; however, the number of vehicles pulled over was left in the discretion of the officers.

The Court of Appeals concluded that the stops violated the Fourth Amendment and constituted unreasonable seizures. In conducting its analysis, the Court found no proof that the means employed was effective in combating crimes against livery drivers or that less intrusive or discretionary means were unavailable. The Court also found there was no fixed format or written guidelines for conducting the stops in question. It should be noted that the Court came to its determination despite the fact, absent here, that the officers were given verbal instructions as to how the stops were to be conducted.