State v. Boone, 180 A.3d 1110

Police conducted month-long surveillance of Akeem Boone for alleged drug distribution and observed hand-to-hand transactions away from his suspected residence at 211 Johnson Avenue.
On the warrant application, Detective Conway identified Boone's residence as "211 Johnson Avenue, Apartment 4A" but provided no facts showing how police knew he lived in Unit 4A (the building had thirty units).
The warrant affidavit detailed surveillance, furtive movements, and past interactions implicating Boone in drug activity but contained no documentary or eyewitness corroboration tying Boone to Unit 4A specifically.
A warrant was issued; police executed the search of Unit 4A and seized cocaine and a handgun; Boone was charged and later pled guilty to drug and weapons offenses after the trial court denied suppression.
The Appellate Division affirmed denial of suppression; the New Jersey Supreme Court granted certification and the Attorney General submitted amicus briefing.
The Supreme Court reversed: it held the warrant affidavit failed to establish probable cause to search Unit 4A because it lacked any factual basis tying Boone or contraband to that particular apartment unit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant affidavit established probable cause to search Unit 4A	State: totality of circumstances (surveillance before/after transactions) justified searching Unit 4A	Boone: affidavit merely labels Unit 4A as his apartment without factual support linking him to that unit or linking unit to criminal activity	Held: affidavit insufficient; no facts tied Unit 4A to Boone or to contraband, so warrant invalid
Whether omission of unit-specific facts can be excused as technical or harmless	State/Amicus: omission was technical; presumption of validity and totality support warrant	Boone: omission fatal; police could have verified residence and must show nexus to place to be searched	Held: cannot infer missing facts; good-faith or technical-error argument rejected under NJ law
Whether probable cause to arrest substitutes for probable cause to search a home	State: surveillance evidence might justify arrest, implying search validity	Boone: arrest probable cause distinct from search probable cause; must show nexus to place	Held: arrest probable cause is distinct; search warrant requires specific facts tying place to evidence
Remedy for invalid warrant (suppression)	State: evidence should stand under totality or harmless-error approaches	Boone: suppression required because warrant invalid and no exception applied	Held: suppression of all evidence seized from Unit 4A; convictions vacated

State v. Chippero, 987 A.2d 555 (distinguishes arrest probable cause from search probable cause)
State v. Keyes, 878 A.2d 772 (warrant upheld where informant and corroborating facts tied defendant to specific unit)
State v. Novembrino, 519 A.2d 820 (rejection of good-faith exception as blanket defense to defective warrants)
State v. Jones, 846 A.2d 569 (totality-of-the-circumstances and the four-corners rule for affidavits)
State v. Marshall, 974 A.2d 1038 (probable cause must appear within the four corners of the affidavit)