State of New Jersey, Plaintiff-Respondent v. William E. Stott, Defendant-Appellant

Summary

The Supreme Court of New Jersey reversed the Appellate Division, holding that the warrantless search of the defendant's psychiatric hospital room violated the Fourth Amendment and that the police lacked a valid exigent‑circumstances or community‑caretaker exception. It also held that the defendant was in custody during police interviews and that his statements obtained without Miranda warnings must be suppressed. The Court emphasized the reasonable expectation of privacy a committed patient has in his room and limited its holding to the facts of this case. Justice LaVECCHIA, concurring in part and dissenting in part, argued that the privacy expectation was diminished and that exigent circumstances justified the search, but agreed with the majority on suppressing the statements.