State v. Al-Sharif Scriven(075682), 140 A.3d 535

Background

At ~3:00 a.m. an Essex County deputy double‑parked behind an unregistered car on Adams Street to investigate and waited on foot for a tow truck. He kept his patrol headlights on but not emergency lights.
A vehicle approached on New York Avenue with its high beams on; it obeyed a stop sign and turned onto Adams when the officer signaled with a flashlight strobe. No other moving vehicles were present.
The officer stopped the car intending to educate the driver about high‑beam use; he did not first tell the driver to dim the lights. Upon contact he smelled marijuana, saw a hollowed cigar, ordered the passenger (Scriven) out, and discovered a handgun after Scriven indicated he had one.
Scriven was indicted for unlawful possession of a handgun and related offenses; he moved to suppress the gun and related items as fruits of an unconstitutional stop.
Trial court granted suppression, concluding the stop violated the Fourth Amendment and N.J. Const. art. I, ¶ 7 because the high‑beam statute applies only when approaching an oncoming vehicle; the officer conceded no oncoming vehicle existed.
Appellate Division affirmed; New Jersey Supreme Court granted review and affirmed the suppression order, holding the statute unambiguous and rejecting community‑caretaking and reasonable‑mistake‑of‑law justifications.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Scriven)	Held
Whether N.J.S.A. 39:3‑60 required dimming when approaching an officer on foot or a parked police car on a perpendicular street	Officer Cohen reasonably believed his parked patrol car/officer on foot constituted an “oncoming vehicle,” justifying the stop	"Oncoming vehicle" means a vehicle approaching in motion; a parked/unoccupied car or an officer on foot is not an oncoming vehicle	Court: Statute unambiguous — "oncoming" means approaching; parked car/officer on foot do not qualify; no violation and no reasonable suspicion to stop
Whether the stop could be justified as an objectively reasonable mistake of law under Heien v. North Carolina	Even if officer misread the statute, Heien allows suppression to be denied when the mistake is objectively reasonable	Officer’s interpretation of the clear statute was not objectively reasonable; Heien inapplicable	Court: Mistake was not objectively reasonable; did not reach whether Heien would apply under NJ Constitution
Whether community‑caretaking doctrine justified the stop (welfare/safety check)	High beams could create a safety hazard to officers and others; officer was performing a caretaking function by warning/dimming lights	Driver’s high‑beam use at normal speed on a well‑lit street did not indicate impairment or medical emergency; no objective basis for welfare stop	Court: Community‑caretaking inapplicable — facts did not show impairment, emergency, or safety hazard requiring a welfare stop
Whether suppression of the handgun and related items was required because the stop was unlawful	Stop was lawful (per State arguments), so evidence admissible	Stop unlawful; evidence is fruit of unconstitutional seizure and must be suppressed	Court: Suppression affirmed — seizure was fruit of unconstitutional stop

Key Cases Cited

Delaware v. Prouse, 440 U.S. 648 (Fourth Amendment requires reasonable, articulable suspicion for traffic stops)
Heien v. North Carolina, 574 U.S. 54 (2014) (under Fourth Amendment an objectively reasonable mistake of law can supply reasonable suspicion)
Cady v. Dombrowski, 413 U.S. 433 (community‑caretaking doctrine described as separate from criminal investigatory functions)
State v. Puzio, 379 N.J. Super. 378 (App. Div. 2005) (erroneous statutory reading cannot provide reasonable basis for stop under NJ law)
State v. Elders, 192 N.J. 224 (2007) (standard of review for suppression hearing findings)
State v. Goetaski, 209 N.J. Super. 362 (App. Div.) (example of welfare‑stop justification under community‑caretaking doctrine)