RAHSAAN RIDDICK, JR. VS. TOWNSHIP OF JACKSON(L-728-14, OCEAN COUNTY AND STATEWIDE), A-1225-15T1

Background

On June 17–18, 2014 Newark detectives used a reliable confidential informant who identified Raymond Wade as selling marijuana from a silver 2001 Buick Century and staying at a named Newark hotel.
Surveillance showed Wade conduct multiple street transactions, stash suspected marijuana under a concrete slab, and retrieve bags from the Buick; officers arrested him after observing these acts and recovered keys and hotel documents linking him to room 332.
A search of the Buick’s glove compartment produced additional suspected marijuana; officers then obtained a warrant to search Wade’s hotel room and executed it, recovering a handgun and other contraband.
Wade moved to suppress the gun and other evidence, arguing the automobile search and his interrogation/consent were unlawful and that material falsehoods in the warrant affidavit required a Franks hearing.
The trial court denied suppression without an evidentiary hearing, finding that even excising the car-search and interrogation material, the affidavit still established probable cause for the warrant.
Wade pled guilty to a weapons offense and appealed the denial of his suppression motion; the Appellate Division affirmed, agreeing the warrant remained valid without the contested material.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wade is entitled to a Franks hearing based on alleged false or coerced statements in the affidavit	Affidavit presumed valid; no deliberate falsehood shown; even if excised, remaining facts support probable cause	Interrogation and vehicle search were unlawful and yielded material facts in the affidavit; consent was coerced and Miranda not given, so affidavit contains tainted material warranting a hearing	Denied Franks hearing; defendant failed to show deliberate falsehood/reckless disregard and excising contested material left probable cause intact
Whether the search warrant was supported by probable cause	Probable cause shown by CI’s reliable tip, surveillance observations, recovery of drugs from stash and vehicle, hotel records tying Wade to room 332	Probable cause derived from evidence obtained via unconstitutional car search and coerced statements, so warrant is invalid	Warrant valid: independent observations and documentary links provided ample probable cause independent of challenged evidence
Whether consent to search (of vehicle) was voluntary	Officers obtained consent for tow-related document retrieval; consent was valid	Consent occurred while in custody and without Miranda/forms, so coerced and invalid	Court credited that officers sought registration/insurance for towing and found drugs; even excluding that, warrant still supported by other affidavit facts
Whether suppression of evidence is required given asserted Miranda/consent violations	State: suppression not required because affidavit otherwise supports probable cause and defendant did not meet Franks standards	Wade: evidence should be suppressed because affidavit relied on unlawfully obtained statements/evidence	Evidence not suppressed; denial of suppression affirmed

Key Cases Cited

Franks v. Delaware, 438 U.S. 154 (establishes standards for requiring a hearing when affidavit contains alleged deliberate falsehoods or reckless disregard for truth)
Miranda v. Arizona, 384 U.S. 436 (establishes requirement to advise suspects of rights prior to custodial interrogation)
State v. Howery, 80 N.J. 563 (places burden on defendant to prove falsity in affidavit by preponderance to obtain Franks hearing)
State v. Frank, 280 N.J. Super. 25 (addresses when a court may decide suppression motions without an evidentiary hearing)