State v. Keaton, 119 A.3d 906

Background

State trooper arrived at scene of an overturned vehicle; driver Duran Keaton had been removed and was receiving EMT treatment for non-life-threatening injuries.
Trooper did not ask Keaton for license/registration or request that Keaton try to retrieve them; instead he entered the overturned car via a rear side window to obtain registration/insurance for a statutorily required accident report.
Inside an open backpack the trooper observed a handgun and a small amount of marijuana; he also recovered Keaton’s ID, insurance, and registration.
Trial court denied Keaton’s suppression motion, concluding the items were legally seized under the plain view doctrine during a search for credentials.
Appellate Division reversed, holding the trooper should have afforded Keaton an opportunity to produce the documents before entering the vehicle.
New Jersey Supreme Court affirmed the Appellate Division: plain view did not apply because officer was not lawfully in the viewing area; inevitable discovery and community-caretaking exceptions failed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Keaton)	Held
Whether plain view justified warrantless entry into overturned car to retrieve registration/insurance	Trooper lawfully searched for credentials needed for statutorily required accident report; contraband was in plain view and discovery was inadvertent	Trooper never gave Keaton an opportunity to produce documents; entry was for officer convenience and thus unlawful	Plain view inapplicable — officer not lawfully in viewing area because Keaton was never afforded opportunity to produce credentials
Whether community-caretaking doctrine permitted search	Trooper acted as community caretaker: obtaining report info and protecting safety justified entry without asking Keaton	Community-caretaking does not extend to searching vehicle for paperwork; no exigency to preserve life/property justified entry	Community-caretaking inapplicable; preparing the accident report is not an exigent circumstance permitting warrantless vehicle search
Whether inevitable discovery would admit the contraband	Contraband would have been discovered via later inventory or tow; thus admissible	No evidence police intended to impound or inventory; State cannot meet clear-and-convincing burden	Inevitable discovery not shown by clear and convincing evidence; exception fails
Scope of permitted search for registration evidence after a traffic/accident stop	Searching areas where registration is normally kept is permissible; entering to retrieve credentials is allowed if driver unwilling/unable to produce them	Officer must first afford driver reasonable opportunity to produce credentials (or get help doing so) before any warrantless entry/search	Warrantless search only permissible after officer affords opportunity and driver is unwilling/unable; rear-of-vehicle search was not justified here

Key Cases Cited

State v. Johnson, 171 N.J. 192 (plain view requires officer to be lawfully in viewing area)
State v. Bruzzese, 94 N.J. 210 (evidence must be discovered inadvertently for plain view to apply)
State v. Boykins, 50 N.J. 73 (officer may search for proof of registration after traffic violation, but scope limited)
State v. Patino, 83 N.J. 1 (search for registration must be reasonable and confined to areas where registration is normally kept)
State v. Jones, 195 N.J. Super. 119 (officer must afford opportunity to retrieve credentials before entering overturned vehicle)
State v. Slockbower, 79 N.J. 1 (privacy interests not subordinated to mere convenience of police)
State v. Sugar, 100 N.J. 214 (standards for inevitable discovery doctrine)
State v. Edmonds, 211 N.J. 117 (scope and narrowness of community-caretaking doctrine)