New York Court of Appeals
The People of the State of New York, Respondent v. James Carvey, Appellant
May 1, 199789 N.Y.2d 707
Summary
The Court affirmed the Appellate Division, holding that police may reach into a vehicle after its occupants have been removed when specific facts—such as a suspect wearing a bullet‑proof vest and furtively placing an object under a seat—indicate an actual and specific danger of a weapon, even absent probable cause. The decision rests on the Court’s established exception to the general rule against post‑frisk intrusions.