STATE OF NEW JERSEY VS. LAWRENCE CARTER, JR. (13-10-3174, CAMDEN COUNTY AND STATEWIDE), A-3994-14T3

Police stopped Carter's car for careless driving and a missing license-plate light; officer ran the plates and confirmed the vehicle was registered to Carter.
During the stop Carter failed to produce registration/insurance despite being asked; officers ordered occupants out, patted them down, and arrested the passenger on outstanding warrants.
An officer searched the center console and glove compartment for registration and discovered a loaded handgun; a later warrant search of the vehicle uncovered additional weapons and contraband.
Carter was tried by jury and convicted on multiple weapons-related counts; sentenced to an aggregate 13-year term with nine years parole ineligibility.
Carter appealed, challenging (1) denial of suppression of the weapons found in the glove compartment search; (2) the court’s Batson/Gilmore analysis of prosecutor’s peremptory strikes; and (3) imposition of consecutive sentences under Yarbough.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of warrantless glove-compartment search for registration	Police may conduct a limited search for ownership documents when driver cannot or will not produce them	Search unlawful because officer already confirmed ownership via plate run; no need to search glove compartment	Search upheld: driver’s refusal to produce documents justified limited search; handgun seized under plain view
Application of plain view doctrine to gun seizure	Gun was lawfully seized because discovered while officer lawfully searching for registration	Seizure violated Fourth Amendment	Held for State: plain view exception applies
Batson/Gilmore challenge to prosecutor’s peremptory strikes	Prosecutor gave race-neutral reasons for strikes (juror relationships, occupation, attitudes toward guns)	Strikes were pretextual and discriminatorily excluded African-American jurors	Trial court’s credibility finding upheld; no Batson/Gilmore violation
Consecutive sentences under Yarbough	Consecutive terms appropriate because certain-persons conviction distinct and would otherwise create a “free crime”	Sentences manifestly excessive; judge misapplied or failed to fully analyze Yarbough factors	Sentences affirmed: court adequately applied Yarbough factors and did not abuse discretion

State v. Holmgren, 282 N.J. Super. 212 (App. Div. 1995) (limited warrantless searches for vehicle papers when registration not produced)
State v. Bruzzese, 94 N.J. 210 (1983) (plain view doctrine principles)
State v. Keaton, 222 N.J. 438 (2015) (driving-documents exception; officer may search for ownership papers if driver cannot or will not produce them)
State v. Pena-Flores, 198 N.J. 6 (2009) (approval of limited searches for registration/proof of ownership during stops)
State v. Boykins, 50 N.J. 73 (1967) (officer may search car for evidence of ownership when driver cannot produce documents)
State v. Patino, 83 N.J. 1 (1980) (driving documents exception precedent)
State v. Osorio, 199 N.J. 486 (2009) (trial-court deference in assessing prosecutor’s reasons for peremptory strikes)
State v. Thompson, 224 N.J. 324 (2016) (appellate standard of review for Batson/Gilmore credibility findings)
State v. Yarbough, 100 N.J. 627 (1985) (factors and guidance for imposing consecutive sentences)
State v. Roth, 95 N.J. 334 (1984) (standard for appellate review of sentencing; abuse of discretion)
Snyder v. Louisiana, 552 U.S. 472 (2008) (trial-court demeanor findings in Batson context entitled to deference)