State v. Edmonds
211 N.J. 117
| N.J. | 2012Background
- A 9-1-1 call reported a domestic dispute possibly involving a handgun at a Carteret residence; Richardson denied any problem and claimed her son was inside alone.
- Police entered the apartment without a warrant to assure the safety of the eleven-year-old, then removed Edmonds from an adjoining room and frisked him.
- A loaded .38 revolver was found under a pillow in the area where Edmonds had been seated; Edmonds claimed the gun was his.
- The trial court suppressed the gun as an unconstitutional warrantless search; Appellate Division affirmed, concluding emergency-aid and caretaking did not justify the search.
- On appeal, the Court held warrantless home searches are presumptively unreasonable and that, once corroboration of the domestic-violence report failed and safety concerns dissipated, a warrantbased probable-cause analysis was required.
- On remand, the trial court nevertheless suppressed the gun, distinguishing the search from Bogan and finding it exceeded the community-caretaking scope; the Appellate Division affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether emergency-aid justifies the warrantless home search | Edmonds contends emergency aid does not authorize a search here | Edmonds' State argues emergency aid permitted a limited weapon search | No; emergency aid insufficient to justify search |
| Whether the community-caretaking doctrine justifies the search of the home | Edmonds argues caretaking does not justify the search for evidence | State argues caretaking allowed limited intrusion to protect occupants | No; caretaking does not justify search here |
| Whether the State carried its burden to justify a warrantless search under the stated exceptions | Edmonds asserts the State failed to prove the search was constitutional | State claims the exceptions applied and the search was reasonable | State failed; suppression affirmed |
Key Cases Cited
- State v. Frankel, 179 N.J. 586 (2004) (three-part emergency-aid test; objective basis required)
- Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency-aid subjective motivation irrelevant; objective reasonableness standard)
- Michigan v. Fisher, 130 S. Ct. 546 (U.S. 2009) (emergency-aid assessed by objective basis)
- State v. Bogan, 200 N.J. 61 (2009) (community-caretaking limited to welfare and safety of child)
- State v. Bruzzese, 94 N.J. 210 (1983) (home searches receive heightened Fourth Amendment protection)
- U.S. v. J.L., 529 U.S. 266 (2000) (anonymous tips require corroboration for reasonable suspicion)
- O’Neal, 190 N.J. 601 (2007) (objective reasonableness governs search-and-seizure analysis)