United States v. Wilson, No. 11-915 (2d Cir. 2012)Annotate this Case
The government appealed from the district court's order suppressing evidence found following the stop and subsequent search of a vehicle driven by defendant. The vehicle stop was executed by two officers of the St. Regis Mohawk Police Department (SRMPD), one of whom was also cross-designated as a U.S. customs officer by ICE. The district court held that the vehicle stop violated the Fourth Amendment because the officers lacked the authority to act as law enforcement officers at the time of the stop. The court held that the violation of the ICE policy requiring prior authorization did not affect the constitutionality of the stop under the Fourth Amendment and that the stop and subsequent search comported with the Fourth Amendment because they were justified by probable cause. Accordingly, the court reversed the decision of the district court. Because the court determined that the stop was a constitutional exercise of designated customs authority, the court did not decide whether the stop was also a constitutional exercise of New York police authority.