Denise Brown, Plaintiff-Respondent v. State of New Jersey and John Steet, Detective (Njsp), Both in His Individual…

Summary

The New Jersey Supreme Court reversed the Appellate Division and reinstated the trial court’s dismissal of Denise Brown’s NJCRA claim, holding that Detective John Steet is entitled to qualified immunity because the law was not clearly established that his warrantless entry to secure Brown’s apartment was unconstitutional. The Court also clarified that police may not rely on Illinois v. McArthur to justify such entry and must secure a home from the outside unless true exigent circumstances exist.