People v Purrier

Holding The court held that placing a suspect in handcuffs during a traffic stop transforms the encounter into a forcible stop and detention, which requires additional justification beyond a mere observation of an unmarked pill bottle. Because the officer could not establish that his partner possessed the requisite level of suspicion to justify the detention, the evidence obtained was suppressed and the indictment was dismissed.

The court’s words

by placing him in handcuffs after directing him to exit the vehicle, the troopers transformed the traffic stop into, at minimum, a "forcible stop and detention"

2026 NY Slip Op 04681, at the official text

that alone is insufficient to justify the forcible stop and detention

2026 NY Slip Op 04681, at the official text

the Trooper's partner did not testify, and the Trooper testified that his partner did not relay the substance of the conversation with the driver to him

2026 NY Slip Op 04681, at the official text