State of New Jersey, Plaintiff-Appellant v. Donald Alston, James Barnes, Harry Williams and Abdullah Khaliq, A/K/A…

Summary

The Supreme Court of New Jersey held that the warrantless search of a stopped automobile after the occupants were arrested was justified under the automobile exception, because probable cause and the vehicle's inherent mobility created exigent circumstances. Accordingly, the trial court's suppression of the two handguns seized was reversed and the case was remanded for trial. The Court also addressed standing, affirming the traditional New Jersey rule that a defendant may rely on a proprietary or possessory interest to challenge a search, while rejecting the federal approach of Rakas.