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PEOPLE v. CUMMINGS

194 A.D.2d 418 (1993)

598 N.Y.S.2d 790

The People of the State of New York, Respondent, v. Crystal Cummings, Appellant

Appellate Division of the Supreme Court of the State of New York, First Department.

June 15, 1993

Contrary to defendant's argument on appeal, the arresting officer's close range observation of defendant dropping two vials of what appeared to be crack cocaine as she exited a known drug location provided probable cause for her arrest (People v McRay, 51 N.Y.2d 594). Therefore, the additional 12 vials of crack cocaine were recovered pursuant to a search incident to a lawful arrest (People v De Santis, 46...

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