State of New Jersey v. Gregory Garcia, A-1606-22

Gregory Garcia, a Wharton Police Department officer, applied for and received firearms permits after undergoing alcohol dependency treatment, answering "no" to questions about alcoholism.
Police received a tip from a confidential FBI source alleging Garcia was stockpiling ammunition, purchasing body armor, and had acquired additional firearms.
A search warrant was issued and executed at Garcia’s residence, resulting in several weapons, ammunition, and large capacity magazines being seized.
Garcia was indicted on various weapons and child endangerment charges; he moved to suppress evidence and challenged the truthfulness of the affidavit supporting the warrant.
Garcia pled guilty to a single count of unlawful possession of a large capacity magazine (LCM) after pretrial motions (including motions to stay pending federal constitutional litigation and Franks hearing requests) were denied; the State dismissed other charges as part of the plea deal.
On appeal, Garcia challenged the validity of the search warrant, denial of Franks hearing, denial of stay, and constitutionality of the LCM statute under the Second Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for warrant	Search warrant was supported by corroborated facts and evidence	Affidavit lacked probable cause and included deficiencies	Warrant valid; probable cause established
Request for Franks hearing	No evidence of deliberate falsehood or reckless disregard	Affiant omitted material facts; misled about alcohol treatment	No substantial showing; hearing not granted
Motion to Stay Proceedings	No irreparable harm; case not based on settled law	Stay needed due to pending federal constitutionality litigation	Stay properly denied
Constitutionality of LCM Law	Not addressed substantively; argument waived via guilty plea	LCM ban violates Second Amendment; should overturn conviction	Second Amendment issue not preserved; waived