New York Court of Appeals

The People of the State of New York, Respondent v. Albert Brown, Appellant

June 17, 197640 N.Y.2d 183

Summary

The Court affirmed the Appellate Division, holding that an oral warrant application recorded by a court reporter satisfies the statutory writing requirement and that the magistrate could assess the informant's credibility without the usual corroboration because the informant testified personally, albeit unsworn. The dissenting judges argued that the lack of oath‑affirmed, written proof of the informant's reliability violated the Fourth Amendment and New York constitutional guarantees, and that the warrant should be invalidated.