State of New Jersey, Plaintiff-Appellant v. Alnesha Minitee, Defendant-Respondent; State of New Jersey…

Summary

The Supreme Court of New Jersey reversed the Appellate Division and reinstated the defendants' robbery convictions, holding that the warrantless search of the SUV was valid under the automobile exception because exigent circumstances existed. The Court distinguished Pena‑Flores, found the search was not a search incident to arrest, and declined to address standing issues. Justice Albin dissented, arguing that the delay of more than three hours destroyed any exigent circumstance justification.