People v Camp-Potter

Holding The court affirmed the denial of the defendant’s motion to suppress evidence, finding that the defendant voluntarily consented to the officers’ entry into his motel room. The appellate court deferred to the trial court’s credibility determination, concluding that the totality of circumstances supported the finding of voluntary consent despite the presence of multiple officers.

The court’s words

law enforcement may lawfully conduct a warrantless search of a premises when they have obtained the voluntary consent of a party who possesses the requisite degree of authority and control over it

2026 NY Slip Op 06352, at the official text

Whether in a particular case an apparent consent was in fact voluntarily given or was in submission to an express or implied assertion of authority, is a question of fact to be determined in the light of all the circumstances

2026 NY Slip Op 06352, at the official text

the totality of circumstances — defendant's prior experience with law enforcement, his apparent cooperation with the officers upon entry, the fact that he was not handcuffed when he gave consent to the officers to enter — supports County Court's finding that defendant voluntarily consented to the officers' initial entry

2026 NY Slip Op 06352, at the official text