Supreme Court of New Jersey

State of New Jersey, Plaintiff-Respondent v. Michael W. Lamb, Defendant-Appellant

May 19, 2014218 N.J. 300

Summary

The Supreme Court of New Jersey affirmed the Appellate Division's denial of the defendant's motion to suppress, holding that the consent to search given by the defendant's mother was knowing, voluntary, and valid despite the stepfather's earlier objection. The Court applied the narrow physical‑presence rule from Randolph and its extension in Fernandez, concluding the stepfather's objection was no longer effective after his removal. The Court also affirmed the defendant's standing under the New Jersey Constitution and found the warrantless search reasonable under the circumstances.