New York Court of Appeals
The People of the State of New York v. Clementin Allen
April 4, 198973 N.Y.2d 378
Summary
The Court affirmed the Appellate Division, holding that the officers' use of handcuffs on the defendant was a permissible non‑arrest detention justified by safety concerns, and therefore the defendant's spontaneous statement was admissible. Justice Titone filed a concurring opinion agreeing with the result but criticizing the majority’s broader language about handcuffing.