State v. Evan Reece (073284), 117 A.3d 1235

Background

Officers responded to a dropped 9-1-1 call from Reece's residence; on arrival Sgt. Delagarza observed three vehicles in the driveway and knocked on the door.
Reece opened the door, denied making the 9-1-1 call, and said he was alone; he retrieved and showed a cordless phone that lacked a 9-1-1 entry.
Delagarza confirmed with dispatch that the call originated from Reece's home, noticed an abrasion on Reece’s hand, and perceived Reece’s demeanor as agitated when asked about marital status.
Delagarza asked to enter; Reece refused, slammed and attempted to lock the door; officers pushed the door open, announced an arrest, and a physical struggle ensued in which officers struck Reece to subdue him.
Reece was charged with two counts of simple assault, resisting arrest, and obstruction; municipal court convicted on assault, resisting, and obstruction; Law Division affirmed resisting and obstruction but acquitted one assault; Appellate Division affirmed resisting and reversed obstruction; New Jersey Supreme Court addressed emergency-aid exception and obstruction on certiorari.

Issues

Issue	State's Argument	Reece's Argument	Held
Whether warrantless entry was justified by the emergency-aid doctrine	Dropped 9-1-1 call creates presumptive emergency; combined with Reece’s denial, multiple cars, hand abrasion, and agitation gave objectively reasonable basis to enter	No sufficient facts to conclude immediate danger; presence in the home heightens Fourth Amendment protection	Entry justified under emergency-aid: dropped 9-1-1 call + observations made entry objectively reasonable
Whether Reece obstructed the administration of law by blocking entry	Officers acted lawfully under emergency-aid; Reece’s slamming/attempt to lock door was physical interference with officers lawfully performing duties	Reece entitled to refuse unlawful entry; refusal not obstruction if entry unlawful	Obstruction conviction reinstated because officers lawfully acted under emergency-aid and Reece physically interfered
Whether Reece properly convicted of resisting arrest	Officers announced arrest and acted under color of authority; resisting is unlawful even if arrest disputed	Arrest/entry were unlawful and officers used excessive force; Reece’s resistance defensive and justified	Resisting-arrest conviction affirmed: announcement + color of authority suffice; no right to resist even if arrest unlawful
Whether excessive force justified Reece’s resistance or vitiates convictions	Force used was necessary to subdue Reece during his resistance; officers perceived threat	Reece argues excessive and multiple blows; force rendered his resistance justified	Court found municipal/Law Division credibility findings supported that officers struck once each and used force reasonably to subdue; excessive-force defense rejected

Key Cases Cited

State v. Frankel, 179 N.J. 586 (N.J. 2004) (dropped 9-1-1 call creates presumptive emergency; emergency-aid test)
State v. Edmonds, 211 N.J. 117 (N.J. 2012) (refines Frankel; two-prong, objective-reasonableness emergency-aid test)
State v. Locurto, 157 N.J. 463 (N.J. 1999) (deference to trial court factual and credibility findings)
State v. Crawley, 187 N.J. 440 (N.J. 2006) (obstruction applies when officer acts in objective good faith; no right to resist investigatory stop)
State v. Williams, 192 N.J. 1 (N.J. 2007) (defendant must submit to investigatory stop even if constitutional validity questioned)
State v. Mulvihill, 57 N.J. 151 (N.J. 1970) (no right to resist arrest even if arrest unlawful; remedies are judicial)