New York Court of Appeals
The People of the State of New York v. Guy F. Scott, Appellant the People of the State of New York v. George Keta
April 2, 199279 N.Y.2d 474
Summary
The Court reversed the Appellate Division decisions in People v. Scott and People v. Keta, holding that warrantless entries onto posted open fields and warrantless administrative inspections of a vehicle dismantling business violate the New York Constitution, article I, § 12, and therefore the evidence must be suppressed. The Court declined to adopt the U.S. Supreme Court’s Oliver open‑fields doctrine and required a reasonable expectation of privacy analysis under state law. A concurrence agreed with the result, while a dissent argued the majority overstepped state constitutional authority.