State of New Jersey, Plaintiff-Respondent v. Gary N. Frankel, Defendant-Appellant

Summary

The Supreme Court of New Jersey affirmed the appellate division, holding that the warrantless entry and limited search of Gary Frankel's home was justified under the emergency aid exception to the warrant requirement. The Court applied its three‑prong test, finding an objectively reasonable basis to believe an emergency existed, that the officers' primary motive was to render aid, and that the search was reasonably related to that emergency. Justice Wallace dissented, arguing the open‑line 9‑1‑1 call and defendant's explanations did not create a sufficient emergency to justify the intrusion.