People v Washington

Holding The court held that police officers executing a search warrant for a vehicle may lawfully detain occupants for a reasonable period to ensure officer safety and prevent flight. Consequently, the suppression of the firearm recovered during a pat-frisk of the defendant was properly denied.

The court’s words

a police officer executing a search warrant is privileged to use reasonable force to effectuate the detention of the occupants of the place to be searched

2026 NY Slip Op 05893, at the official text

the rationale for such forcible detention is a fear that the [person] may interfere with the execution of a search warrant

2026 NY Slip Op 05893, at the official text

the detention of defendant for, at most, 45 minutes was lawful

2026 NY Slip Op 05893, at the official text

the scope of the warrant and the circumstances surrounding its execution warranted a frisk of occupants without a separate particularized suspicion of criminality

2026 NY Slip Op 05893, at the official text