State V.charles Bryant,jr.(075958)(middlesex County and Statewide), 148 A.3d 398

At ~3 a.m., an intoxicated woman called 911 saying she had been assaulted and gave only an address; she did not identify herself or the assailant.
Two officers went to the apartment, knocked, and defendant Charles Bryant answered; he was told to sit on the couch and officers entered.
While one officer questioned Bryant, another conducted a warrantless protective sweep of the unit (bedroom, bathroom, kitchen, closet).
During the sweep the officer smelled and observed what he believed to be marijuana in a closet, seized it, arrested Bryant, and secured a search warrant.
The warrant search recovered an assault weapon, ~55 grams of marijuana, and packaging materials; Bryant moved to suppress all evidence as the product of an illegal search.
Trial court and Appellate Division upheld the protective sweep; the New Jersey Supreme Court reversed, holding officers lacked reasonable, articulable suspicion to justify the sweep and suppressed the evidence as fruit of the poisonous tree.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bryant)	Held
Lawfulness of warrantless entry/protective sweep	Entry and sweep lawful: domestic-violence context plus unknown identity created reasonable, articulable suspicion of others/weapon(s)	Officers had no consent or exigency; mere uncertainty/hunch insufficient for protective sweep	Protective sweep unlawful — officers lacked reasonable, articulable suspicion that anyone else was present or dangerous
Plain view and downstream warrant validity (fruit of the poisonous tree)	Marijuana was in plain view during a lawful sweep; subsequent warrant and seizures valid	Evidence was discovered during an unlawful sweep, so subsequent warrant and seizures are tainted	Evidence (initial and obtained via subsequent warrant) suppressed as fruits of the unconstitutional sweep

State v. Davila, 203 N.J. 97 (N.J. 2010) (adopts two-part protective-sweep test under NJ law)
Maryland v. Buie, 494 U.S. 325 (U.S. 1990) (protective sweep doctrine allows cursory search for persons posing danger)
State v. Edmonds, 211 N.J. 117 (N.J. 2012) (preference for warrants; state burden to justify warrantless searches)
State v. Johnson, 193 N.J. 528 (N.J. 2008) (New Jersey Constitution often affords greater search-and-seizure protections)
State v. Pineiro, 181 N.J. 13 (N.J. 2004) (no mechanical formula for reasonable suspicion; burden on State)
State v. Burris, 145 N.J. 509 (N.J. 1996) (exclusionary rule as remedy for unconstitutional searches)
State v. Gibson, 218 N.J. 277 (N.J. 2014) (fruit-of-the-poisonous-tree doctrine excludes evidence from unlawful searches)