STATE OF NEW JERSEY VS. TAAREEF ROBINSON(14-02-0173, MERCER COUNTY AND STATEWIDE), A-4082-15T1

A confidential informant (CI) with prior reliable tips told police that "Slick" (defendant Taareef Robinson) was selling cocaine and lived at an Elmer Street address in Trenton.
The CI arranged two controlled buys: officers searched the CI and his vehicle beforehand, supplied buy money, and observed both hand-to-hand transactions; the CI delivered suspected cocaine to officers after each buy.
Detective Castaldo observed a man matching the CI's description leave the Elmer Street house, meet the CI, enter the CI's car briefly, then return to the Elmer Street house after both transactions.
The purchased substances tested positive for cocaine. Based on the affidavit recounting these buys and observations, a warrant was issued to search Robinson’s person and residence.
The search uncovered drugs, cash, and a shotgun; Robinson confessed the items were his and was charged. He moved to suppress, arguing the affidavit was internally contradictory and sought a Franks hearing; the trial court denied the motion.
Robinson pleaded and appealed, arguing the affidavit’s alleged contradictions required a Franks hearing or outright suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a Franks hearing was required to challenge the affidavit’s veracity	State: affidavit presumed valid; defendant failed to make a substantial preliminary showing of intentional or reckless falsehood	Robinson: affidavit contained a material contradiction (that CI and car were "drug and money free"), showing reckless falsehood requiring a Franks hearing	Denied — no substantial showing of falsehood; no Franks hearing required
Whether the alleged contradiction fatally undermined probable cause	State: affidavit described two corroborated controlled buys and officer surveillance supporting probable cause	Robinson: the statement that CI and car were "drug and money free" after the buys contradicts the presence of purchased drugs, nullifying corroboration	Denied — plain reading shows no contradiction; affidavit established probable cause
Standard of review for denial of evidentiary hearing	State: trial court’s decision reviewed for abuse of discretion; factual findings upheld if supported by credible evidence	Robinson: urged reversal based on alleged clear error in denying suppression and Franks hearing	Affirmed — appellate deference; no clear mistake warranting reversal
Burden to overturn warrant-based search	State: defendant bears burden to prove lack of probable cause or unreasonable search	Robinson: argued burden met via alleged affidavit contradictions	Denied — defendant did not meet burden

Franks v. Delaware, 438 U.S. 154 (establishes standard for when a defendant is entitled to an evidentiary hearing on alleged false statements in a warrant affidavit)
State v. Broom-Smith, 406 N.J. Super. 228 (app. div. 2009) (discusses Franks standard and when hearings are required)
State v. Gamble, 218 N.J. 412 (2014) (appellate review standard for suppression factual findings)
State v. Elders, 192 N.J. 224 (2007) (reversal only for clearly mistaken suppression rulings)
State v. Howery, 80 N.J. 563 (1979) (New Jersey’s adoption of Franks procedures)
State v. Jones, 179 N.J. 377 (standard that search pursuant to warrant is presumed valid)
State v. Valencia, 93 N.J. 126 (burden on defendant to show lack of probable cause)
State v. Marshall, 123 N.J. 1 (appellate deference to warrant issuance)
State v. Kasabucki, 52 N.J. 110 (discusses deference to magistrate’s probable cause determination)