State of New Jersey, Plaintiff-Appellant v. Lucio W. Patino and Guillermo Barriga, Defendants-Respondents

Summary

The Supreme Court of New Jersey affirmed the Appellate Division’s suppression of cocaine seized from the automobile trunk, holding that neither the search‑incident‑to‑arrest doctrine nor the automobile exception justified the warrantless search because no probable cause existed. The Court also held that the pre‑Prouse random stop was not subject to retroactive application of Prouse. Justice Schreiber dissented, arguing that the officer had sufficient suspicion to search the trunk and that the convictions should be reinstated. Justice Pashman concurred in the result but contended that the Prouse rule should apply retroactively and that the search of the shopping bag was also unlawful.