State v. Alston

The Supreme Court of New Jersey
88 N.J. 211, 440 A.2d 1311 (1981)

ELI5:

Rule of Law:

Under the automobile exception, police with probable cause to believe a lawfully stopped vehicle contains contraband may conduct an immediate warrantless search of the vehicle, even after its occupants have been arrested and secured. Further, under the New Jersey Constitution, a defendant has automatic standing to challenge a search if charged with a possessory offense for the items seized.

Facts:

Bergen County Police Detectives Fenech and Schmidig pursued a speeding Buick automobile driven by defendant Alston with three other occupants.
During the chase, the officers observed the occupants moving about inside the vehicle as if attempting to conceal something.
After stopping the car, Alston opened the glove compartment to retrieve vehicle credentials, at which point an officer observed three shotgun shells inside.
The four occupants were ordered out of the car and patted down for weapons.
An officer returned to the vehicle to retrieve the shells and observed an opaque plastic bag protruding from under the front passenger seat.
The officer felt the bag, determined it 'felt like a gun,' opened it, and discovered a sawed-off shotgun.
The four occupants were then placed under arrest and handcuffed.
A subsequent search of the vehicle's passenger compartment uncovered a revolver under the front seat and another loaded revolver wedged in the back seat.

Procedural Posture:

Defendants Alston, Barnes, Williams, and Khaliq were charged in trial court with unlawful possession of weapons.
The defendants filed motions to suppress the three weapons seized from the car.
The trial court granted the defendants' motions, suppressing all three weapons.
The State (appellant) appealed to the Appellate Division.
The Appellate Division reversed the suppression of the sawed-off shotgun but affirmed the suppression of the two revolvers.
The State (appellant) was granted leave to appeal to the Supreme Court of New Jersey concerning the suppression of the two revolvers; the defendants' (appellees) cross-motion regarding the shotgun was denied.

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Issue:

Does the automobile exception to the Fourth Amendment's warrant requirement permit a warrantless search of a vehicle's passenger compartment for additional weapons after the occupants have been arrested, handcuffed, and removed from the vehicle?

Opinions:

Majority - Justice Clifford

Yes, the automobile exception permits a warrantless search of a vehicle's passenger compartment even after the occupants have been arrested and secured. The court first established that the defendants had standing to challenge the search under the New Jersey Constitution. Departing from recent U.S. Supreme Court precedent in Rakas v. Illinois, the court retained the 'automatic standing' rule from Jones v. United States, which grants standing to any defendant charged with a possessory offense involving the seized evidence. On the merits of the search, the court held that the discovery of the shotgun shells and the sawed-off shotgun provided probable cause to believe other weapons were hidden in the vehicle. Following Chambers v. Maroney, the court reasoned that the 'exigent circumstances' justifying the automobile exception arise from the inherent mobility of the vehicle itself, a condition that does not dissipate merely because the occupants have been arrested and removed. Therefore, the police could either search the car immediately on the scene or seize it and search it later; both actions are constitutionally reasonable.

Concurring - Justice Schreiber

Yes, but the majority's reasoning on standing is flawed and unnecessary. The concurrence agrees that the search was constitutional because there was probable cause, making the discussion of standing irrelevant to the outcome. It argues that the court should have followed the U.S. Supreme Court's abandonment of the 'automatic standing' rule in United States v. Salvucci, as the original justification for the rule (protecting the Fifth Amendment right against self-incrimination) has been eliminated. By creating a broader standing rule under the state constitution, the majority unnecessarily parts company with federal jurisprudence, ignores the core Fourth Amendment principle of a 'reasonable expectation of privacy,' and provides a 'windfall' to defendants whose rights were not actually violated.

Analysis:

This case is a landmark decision in New Jersey constitutional law, establishing that the state constitution provides greater protection against unreasonable searches and seizures than the Fourth Amendment on the issue of standing. By explicitly rejecting the U.S. Supreme Court's restrictive standing doctrine and retaining 'automatic standing' for possessory offenses, the court solidified New Jersey's role in providing independent state constitutional protections. The decision also clarified the scope of the automobile exception in New Jersey, holding that the exigency stems from the vehicle's mobility itself, not the occupants' ability to access it, thus giving law enforcement clear authority to conduct a full passenger compartment search based on probable cause even after an arrest.

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