State v. Chisum, 200 A.3d 1279

Police responded to a noise complaint at a motel room (Room 221); the renter, Zykia Reevey, immediately turned down the music and invited officers inside.
Officers observed about ten occupants in the room, called for backup, and kept the door partially open while speaking to occupants.
Although no summons was issued (officers opted to warn), officers requested identification from all occupants and ran warrant checks via dispatch; occupants were detained until checks cleared.
Approximately 20+ minutes into the detention, dispatch returned a positive warrant hit for Deyvon Chisum; officers arrested him, searched him incident to arrest, and found a handgun.
After finding Chisum’s gun, officers ordered a weapons frisk of remaining occupants; a pat-down of Keshown Woodard revealed a second handgun.
Defendants’ motions to suppress were denied by the trial court and the Appellate Division; the Supreme Court reversed, holding the continued detention and warrant checks were unconstitutional and suppression required withdrawing guilty pleas.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether continued detention/warrant checks were lawful after noise was abated	Chisum: once music was turned down and no summons issued, no reasonable suspicion remained to detain occupants or run warrant checks; checks unrelated to noise complaint	State: noise ordinance applied to all occupants; officers reasonably suspected violation and could lawfully ascertain identities and run checks as part of the stop (officer safety, potential callback, and discretionary decision to warn)	Detention unlawful: after noise abated and officers declined to issue summons, reasonable suspicion ended; running warrant checks and detaining occupants was not related to the completed mission and violated Fourth Amendment/State constitution
Whether pat-down of Woodard was justified	Woodard: no individualized, particularized suspicion he was armed; mere proximity/association to Chisum insufficient	State/AG: totality (motel reputation, time, number of occupants, recovery of gun from Chisum) made frisk reasonable for officer safety	Pat-down unlawful as fruit of unconstitutional detention; frisk not salvageable because the prior detention and warrant-check seizure were illegal

Terry v. Ohio, 392 U.S. 1 (establishes investigatory stop and reasonableness/suspicion framework)
United States v. Sharpe, 470 U.S. 675 (no rigid time limit on Terry stops; courts assess diligence and reasonableness of duration)
Illinois v. Caballes, 543 U.S. 405 (a seizure lawful at inception can become unconstitutional by manner/duration of execution)
Maryland v. Buie, 494 U.S. 325 (frisk/limited protective sweeps require reasonable, individualized suspicion)
State v. Coles, 218 N.J. 322 (investigative stop must be reasonable at inception and reasonably related in scope/duration)
State v. Rosario, 229 N.J. 263 (Terry principles under New Jersey law)
State v. Shaw, 213 N.J. 398 (high-crime-area reputation alone cannot justify random stops or frisks)
State v. Pineiro, 181 N.J. 13 (warrantless searches/seizures presumptively invalid; State bears burden to justify exception)
State v. Dickey, 152 N.J. 468 (assesses when a seizure exceeds bounds of an investigative stop)