State of New Jersey, Plaintiff-Appellant v. Amir Randolph, Defendant-Respondent

Summary

The Supreme Court of New Jersey affirmed the Appellate Division’s decision that defendant Amir Randolph had automatic standing to challenge the warrantless search of a second‑floor apartment because he faced possessory drug charges, and that the State failed to show the apartment was abandoned or that he was a trespasser. The Court held that the trial court erred in its standing analysis and remanded for a new suppression hearing to determine whether exigent‑circumstances or a protective sweep justified the entry. It also held that the trial court’s failure to give a "mere presence" jury instruction did not constitute reversible error, so the appellate order granting a new trial on that ground was reversed.