State of New Jersey v. Jose E. Rodriguez, A-0845-22

Jose E. Rodriguez was convicted for first-degree possession with intent to distribute marijuana, third-degree possession of cocaine, and fourth-degree possession of marijuana in New Jersey after a controlled delivery operation that began with a traffic stop in Illinois.
Rodriguez challenged the admissibility of both physical evidence (marijuana, cocaine, cash) and statements made to police, claiming his Fourth and Fifth Amendment rights were violated.
The Illinois stop and search occurred due to a traffic violation; New Jersey law enforcement later orchestrated a controlled delivery involving Rodriguez.
The trial court admitted evidence obtained during and after these events, found some Miranda violations but upheld the validity of Rodriguez’s signed consent-to-search forms.
On appeal, Rodriguez also challenged his sentence, specifically arguing for merger of certain offenses and disputing the application of certain aggravating sentencing factors.
The State conceded that some convictions should be merged, and the appellate court affirmed in part, remanded in part for resentencing, and found no error on the key suppression issues.

Issue	Rodriguez's Argument	State's Argument	Held
Suppression of evidence from Illinois stop	Illinois stop/search violated NJ constitutional standards, requiring exclusion	Illinois law controls for Illinois stop; search was based on probable cause for a traffic violation	New Jersey law does not apply; Illinois stop/search was justified; evidence admissible
Need for anticipatory warrant for controlled delivery	Police should have obtained an anticipatory warrant before delivering marijuana in NJ	Probable cause for warrant did not exist until Rodriguez took possession; warrant not required at earlier stage	No anticipatory warrant was required; search was reasonable under circumstances
Suppression of evidence as fruit of Miranda violation	Miranda violations tainted all subsequent evidence and statements; all should be suppressed	Only unwarned custodial statements suppressed; written consent to search was voluntary, physical evidence remains admissible	Unwarned statements suppressed; consent and physical evidence validly admitted
Sentencing/merger and aggravating factors	Court erred in not merging offenses and misapplied aggravating factors (especially cruelty/heinousness)	Some convictions should be merged, but aggravating factors were applied appropriately	Merger required for some convictions; improper use of aggravating factor 1 (cruel/heinousness); remand for resentencing

Miranda v. Arizona, 384 U.S. 436 (Fifth Amendment Miranda warning requirements for custodial interrogation)
Illinois v. Gates, 462 U.S. 213 (Totality-of-the-circumstances approach to probable cause determinations)
Whren v. United States, 517 U.S. 806 (Traffic stops are valid if police have probable cause for a violation)
State v. Robinson, 200 N.J. 1 (Standard of appellate review for suppression motions)
State v. Rivas, 251 N.J. 132 (Appellate deference to trial courts’ factual findings in suppression hearings)
State v. Fuentes, 217 N.J. 57 (Guidance on sentencing and proper use of aggravating factors)
State v. Roth, 95 N.J. 334 (Appellate review standard for sentencing determinations)