State of New Jersey, Plaintiff-Appellant v. Juan Pena-Flores, A/K/A Juan C. Penaflores, A/K/A Juan C. Flores, A/K/A…

Summary

The Court reaffirmed that a warrantless automobile search is permissible only when police have probable cause and a case‑by‑case finding of exigent circumstances. Applying that standard, the Court reversed the suppression ruling in State v. Pena‑Flores, finding exigent circumstances, and partially affirmed and partially reversed the ruling in State v. Fuller, holding that only evidence discovered incident to a search for vehicle registration was admissible. The decision also articulated a multi‑factor test for determining exigency and directed amendment of warrant‑request rules.