State of New Jersey, Plaintiff-Appellant v. Tawian Bacome, Defendant-Respondent

Summary

The Supreme Court of New Jersey affirmed that a lawful traffic stop based on a seat‑belt violation is valid and that, under the Smith heightened‑caution standard, police may order a passenger to exit a vehicle when specific, articulable facts create a heightened danger to officers. Applying that standard to the defendant’s furtive movements, the Court held the passenger’s removal was lawful, the plain‑view observation of narcotics was proper, and the conviction was reinstated.