State v. Hathaway
120 A.3d 155
| N.J. | 2015Background
- Defendant Hathaway’s hotel room was entered without a warrant after a patron reported an armed robbery on the 70th floor of the Taj Mahal.
- Police, facing a potentially armed gunman and urgent risk to patrons, proceeded with SWAT back‑up and entered Room 7023 when the door was found ajar and no one answered.
- A wide‑open duffel bag in the room contained an automatic handgun and documents tied to Hathaway, and the gun was observed in plain view by officers.
- The room was registered to Hathaway; he was later arrested there for unlawful possession of a firearm.
- The trial court suppressed the gun, finding lack of probable cause or exigent circumstances; the Appellate Division affirmed suppression.
- The Supreme Court reversed, holding the emergency‑aid doctrine justified entry and the gun’s seizure, and remanded for a new suppression hearing with fuller witness participation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether emergency-aid justifies warrantless entry | State argues emergency-aid applies due to imminent danger and the search was reasonable. | Hathaway contends there were no ongoing crimes or exigent circumstances; no basis to bypass a warrant. | Emergency‑aid justified entry; gun admissible |
| Reliability of informant and corroboration requirements | State contends patron’s in‑person report to security was reliable and corroborated by surveillance. | Hathaway argues third‑hand, unverified information cannot support exigency. | Totality of circumstances supported reliability |
| Scope of the emergency search | State asserts search limited to finding victims or a gun, which is permissible under emergency aid. | Hathaway maintains narrow scope; police could not extend beyond initial purpose. | Search scope properly limited to safety and weapon discovery |
| Plain-view seizure was proper | Gun observed in plain view during lawful entry may be seized. | No separate challenge to plain view; focus is on entry legality. | Weapon admissible in plain view during lawful otherwise permissible entry |
Key Cases Cited
- State v. Pena-Flores, 198 N.J. 6 (2009) (exigent-circumstances framework for warrants)
- Stoner v. California, 376 U.S. 483 (1964) (hotel-room searches require warrants where feasible)
- Frankel v. State, 179 N.J. 586 (2004) (emergency-aid doctrine as life-preserving exception)
- Edmonds, 211 N.J. 117 (2012) (two-prong test for emergency-aid: basis and nexus)
- Basil, 202 N.J. 570 (2010) (face-to-face informant reliability; credibility in EMS/informant context)
- Golotta, 178 N.J. 205 (2003) (9-1-1 tips and presence of threat justify prompt action)
- J.L. v. United States, 529 U.S. 266 (2000) (anonymous tips and reliability considerations)
- Edmonds, 211 N.J. 117 (2012) (emergency-aid doctrine two-prong test)
- United States v. De Cesaro, 502 F.2d 604 (7th Cir. 1974) (reliability of information transmitted by police sources)
- United States v. Martins, 413 F.3d 139 (1st Cir. 2005) (emergency-aid as a subset of exigent circumstances)