STATE OF NEW JERSEY VS. FRANCIS G. LANGLEY(13-07-0720 AND 15-01-0008, CAPE MAY COUNTY ANDSTATEWIDE), A-5129-15T1

Police responded to a 9-1-1 report of a domestic dispute at defendant Francis Langley’s home; neighbor reported prior disturbance and forced entry.
Officers found Langley and his wife (N.L.); N.L. appeared distraught and told officers Langley told her to get a shotgun and kill herself. Children had fled the home.
Langley admitted he had told his wife that and volunteered that an unloaded shotgun was under the bed and a crossbow in his closet; he also acknowledged a prior felony conviction on officers’ questioning.
Officers seized the shotgun and crossbow, ran a criminal-history check (revealing felony convictions), then later arrested Langley. No Miranda warnings were given before his admissions.
Langley pleaded guilty pursuant to a deal, was sentenced to concurrent terms, moved (unsuccessfully) to suppress the physical evidence and his statements, and later moved to withdraw his plea; appellate court affirmed denial of all motions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Suppression of weapons seized from home	Seizure justified by emergency-aid/community-caretaking exception given reasonable belief N.L. might be suicidal	Seizure impermissible under PDVA and community-caretaking; evidence should be suppressed	Denial of suppression affirmed: emergency-aid exception justified warrantless search and seizure
Use of unadmitted materials in judge’s written opinion	Judge relied on hearing testimony and available briefs; no prejudice	Judge relied on unadmitted police reports and 9-1-1 calls not in the record	Denial affirmed: hearing testimony sufficed; parties’ briefs and appendix materials were before court; no plain error
Suppression of defendant’s statements (Miranda)	Statements were volunteered in noncustodial context in defendant’s home; Miranda unnecessary	Statements taken without Miranda warnings and after move to another room; custodial interrogation required warnings	Denial affirmed: totality of circumstances shows noncustodial encounter; Miranda not required
Motion to withdraw guilty plea	Plea was knowing; State would be prejudiced by withdrawal; defendant was warned State would oppose bail	Defendant claims ineffective advice re: bail pending appeal and asserts innocence (shotgun belonged to son)	Denial affirmed under Slater factors: no credible innocence claim; plea knowing; State would be prejudiced; attorney-claim more appropriate for PCR

Rockford v. State, 213 N.J. 424 (review standard for suppression factual findings)
Edmonds v. State, 211 N.J. 117 (limits warrantless home entries absent exigent circumstances; emergency-aid analysis)
Vargas v. State, 213 N.J. 301 (community-caretaking vs emergency-aid distinction)
Hathaway v. State, 222 N.J. 453 (two-prong emergency-aid test; totality of circumstances)
Frankel v. State, 179 N.J. 586 (emergency-aid doctrine background)
Sloane v. State, 193 N.J. 423 (criminal-history checks are not searches)
Slater v. State, 198 N.J. 145 (four-factor test for plea-withdrawal motions)
Miranda v. Arizona, 384 U.S. 436 (Miranda custodial-interrogation rule)