State v. Kevin Gamble (071234), 218 N.J. 412

Late-night (≈11:00 p.m.) police response to two anonymous calls in a high‑crime Irvington, NJ area: one reporting “shots fired,” another (a 9‑1‑1 call) reporting a person seated in a tan van with a gun in his lap.
Officers located a tan van at the reported location, shone a spotlight on it, exited with weapons drawn, and observed occupants making frantic/furtive movements.
Officer Bryant ordered occupants out; passenger exited, driver (Gamble) began to exit then retreated to the driver’s seat; Bryant forcibly removed and frisked Gamble and (apparently) the passenger; no weapons found on their persons.
As Bryant returned to the van, he observed the handle of a handgun protruding from the center console, heard Gamble attempt to flee, and the handgun was recovered after Gamble was subdued.
Gamble was charged; trial court denied suppression (finding totality of circumstances and plain view justified seizure); Appellate Division reversed; New Jersey Supreme Court granted certification and reversed the Appellate Division, upholding the stop and narrowly confined protective sweep.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Gamble)	Held
Were officers justified in stopping the van?	9‑1‑1 anonymous call(s) identifying vehicle + corroboration, late hour, high‑crime area, furtive movements created reasonable suspicion.	Anonymous tip insufficient; corroboration here was minimal; stop lacked requisite reasonable suspicion.	Stop was justified under the totality of circumstances (9‑1‑1 calls, location/time, corroboration, furtive movements).
Was a protective frisk/sweep of vehicle permissible?	Officer reasonably suspected occupants could access a weapon (driver’s balk/retreat + earlier tip); limited visual sweep for weapons was necessary for safety.	Protective‑sweep doctrine inapplicable or insufficient here; no ongoing exigency; occupants already frisked/arrested.	Narrowly confined visual sweep of passenger compartment was permissible; officer had articulable suspicion driver/vehicle posed danger.
Did plain‑view doctrine independently justify seizure of the gun?	Trial court invoked plain view; State also argued plain view and urged abandonment of inadvertence requirement.	Officer did not see the gun before entering; discovery was not inadvertent.	Court did not decide plain view question because protective sweep was sufficient; declined to resolve inadvertence argument.
Standard of review for suppression rulings?	N/A (procedural)	N/A	Trial court factual findings get deference if supported by credible evidence; legal conclusions reviewed de novo.

Terry v. Ohio, 392 U.S. 1 (Terry stop and frisk standard)
Maryland v. Buie, 494 U.S. 325 (limited protective sweeps of premises incident to arrest)
Michigan v. Long, 463 U.S. 1032 (protective search of vehicle passenger compartment)
Alabama v. White, 496 U.S. 325 (anonymous tip reliability analysis)
Florida v. J.L., 529 U.S. 266 (anonymous tip insufficient for frisk when no indicia of reliability)
United States v. Sokolow, 490 U.S. 1 (reasonable suspicion lower than probable cause)
State v. Davila, 203 N.J. 97 (NJ application of protective‑sweep principles)
State v. Golotta, 178 N.J. 205 (treated 9‑1‑1 calls as more reliable and sufficient to justify certain investigative stops)
State v. Lund, 119 N.J. 35 (factors including furtive gestures and late hour can contribute to reasonable suspicion)