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Sibron v. New York was never consolidated with Terry v. Ohio, instead it was consolidated with Peters v. New York.

In the case of Sibron v. New York, an NYPD Officer observed Nelson Sibron speaking with drug addicted citizens. At this point he performed a Terry Stop on Sibron where he observed the defendant sticking his hands into his pocket. The Officer proceeded to rip his hand out of his pocket and revealed multiple envelopes containing narcotics. He was subsequently arrested and charged with drug trafficking.

After a failed motion and appeal to have the evidence suppressed, the supreme court granted certiorari (legal review) and heard the case. In an 8-1 decision the court ruled in favor of Nelson Sibron on the basis that the officer never heard the conversation between the defendant and the drug addicts and thus the Terry Stop, which uncovered the drugs, was invalid. It also ruled that the search was invalid because the officer involved with the stop testified that he had no reasonable suspicion to believe that Sibron was armed with a weapon.

However, Peters v. New York worked out differently. Peters was arrested and later convicted for intent to commit burglary. An on duty officer observed Peters prowling inside an apartment building. When the officer approached Peters to question him about being there, he fled on foot. After the officer caught him and cuffed him, a terry search revealed the burglary tools. The supreme court held that because he ran from the officer he gave the officer probable cause to search him. Thus his conviction was enforced.

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Q: Why was Sibron v New York case consolidated with Terry v Ohio?
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