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 Supreme Court of New Jersey reversed the Appellate Division’s suppression of most of the evidence seized from Juan Pena‑Flores’s vehicle, holding that probable cause and exigent circumstances justified a warrantless automobile search, and affirmed in part and reversed in part the Appellate Division’s decision in the Fuller case, allowing the seizure of a handgun and prescription drugs discovered while searching for registration but suppressing other items because no exigent circumstances existed. The Court also issued a dissent warning that the new multi‑factor exigency test will unduly burden law enforcement.