State of New Jersey, Plaintiff-Appellant v. Drew Johnson, Defendant-Respondent

Summary

The Supreme Court of New Jersey held that the police satisfied all three elements of the plain view doctrine—lawful presence on the porch, inadvertent discovery, and probable cause to associate the object with contraband—thereby reversing the trial court’s suppression order and remanding for further proceedings. The Court adopted the Texas v. Brown standard that probable cause, not certainty, is sufficient for plain view. Justice LONG dissented, arguing that no probable cause existed and the plain‑view doctrine was not satisfied.