Supreme Court of New Jersey
State of New Jersey v. Melvin T. Dickerson, Defendant-Respondent.
February 5, 2018232 N.J. 2
Summary
The Supreme Court of New Jersey held that Rule 3:4-2(c)(1)(B) does not impose a blanket duty on the State to produce a search‑warrant affidavit at a pretrial detention hearing; disclosure is required only when the affidavit relates to the State’s presentation, and the trial court’s sanction of releasing the defendant for failure to produce the affidavit was improper. The Court reversed the Appellate Division’s order compelling production and affirmed the remand for a full detention hearing. Justice Albin dissented, arguing that the affidavit should be disclosed absent confidentiality concerns.