State v. Antoine D. Watts(074556), 126 A.3d 1216

Background

Police obtained a warrant authorizing a no-knock entry of 224 Third Street (apt. 4) and a search of Antoine Watts’s person for heroin and drug paraphernalia.
Officers surveilled Watts, detained him about 1.5 blocks from his apartment as he exited a liquor store, patted him down for weapons, and removed his apartment keys.
Officers declined an intrusive public search (due to dignity and safety concerns), handcuffed Watts, and transported him in an unmarked car back to the apartment while two detectives used the keys to enter.
Upon arrival at the apartment, as Watts walked under police escort, four bundles of heroin fell from his pant leg; six minutes elapsed from detention to discovery.
Trial court suppressed the heroin, concluding police impermissibly detained and re-searched Watts after an initial street search; Appellate Division affirmed.
The New Jersey Supreme Court reversed, holding the short detention and completion of the person-search in a secure location were objectively reasonable under the Fourth Amendment and NJ Constitution.

Issues

Issue	State's Argument	Watts's Argument	Held
Whether continued detention and completion of a person-search after a limited street pat‑down violated the Fourth Amendment / NJ Const.	The warrant included authority to search Watts’s person; a limited frisk for weapons and seizure of keys was reasonable and officers could transport him to a secure location to finish the search.	Once the officers conducted a search outside the liquor store and found no contraband, they had to release Watts; a second search elsewhere was unauthorized and unconstitutional.	The Court held the detention and completion of the search at a more private location were objectively reasonable; the limited street frisk did not foreclose continuing the authorized search.
Whether officers were required to conduct a full, intrusive search at the initial public detention site.	Officers reasonably declined a more intrusive public search because of dignity and safety concerns and could complete the search in a controlled setting.	The initial search exhausted the warrant’s authorization at that site; moving Watts and searching again violated protections against unreasonable searches.	The Court rejected an all‑or‑nothing rule; officers may defer intrusive components to a secure location when reasonable.
Whether Bailey v. United States governs and bars the detention/search here.	Bailey is inapplicable because the warrant here expressly authorized a search of the person (not only the premises).	Bailey should apply to limit warrant‑execution detentions of occupants who have left the premises.	The Court declined to apply Bailey because that case involved warrants for the premises only; here the warrant covered Watts’s person.

Key Cases Cited

Florida v. Royer, 460 U.S. 491 (1983) (scope and tailoring of detention/search must correspond to justification)
Illinois v. Lafayette, 462 U.S. 640 (1983) (more intrusive or embarrassing searches may be performed in private settings)
United States v. Ross, 456 U.S. 798 (1982) (lawful search of premises extends to areas where the object may be found)
Chimel v. California, 395 U.S. 752 (1969) (search incident to arrest scope)
United States v. Knights, 534 U.S. 112 (2001) (reasonableness is the Fourth Amendment touchstone)
State v. Edmonds, 211 N.J. 117 (2012) (preference for warrants; exceptions narrowly applied)
State v. Hathaway, 222 N.J. 453 (2015) (reasonableness standard and deference considerations)