State v. MINITEE, 44 A.3d 1100

Defendants Bland and Minitee were charged with a series of robberies in multiple counties; Minitee elected trial and was convicted on five counts, Bland pled guilty to one count.
Police pursued a red SUV after an armed-robbery report; Bland exited with a gun and handbag, then fled; the SUV was later stopped at a dead-end, with Minitee and Jones nearby.
Two rolls of duct tape were observed in the SUV, consistent with the robbery victims being bound; the SUV was linked to Minitee as the registered owner.
The SUV and occupants were taken to police headquarters; the SUV was towed and later searched by Bergen County Bureau officers without a warrant.
Evidence found in the SUV included duct tape, massage-parlor ad pages, a videotape of a prior robbery, a gun-related item, and other items tying the defendants to the crimes.
The trial court denied suppression; the Appellate Division reversed, concluding the search was impermissible as part of Pena-Flores and vacated convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the SUV search at headquarters within the automobile exception	Minitee argues Pena-Flores controls; exigency insufficient	Minitee contends automobile exception requires exigent circumstances; not satisfied	Yes, within automobile exception; exigency present
Did Bland have standing to challenge the SUV search	Bland had standing as a passenger with rights in the vehicle	Bland lacked proprietary/participatory interest	Not necessary to decide; search upheld on other grounds
Does Pena-Flores govern the analysis of exigent circumstances here	Appellate Division misapplied Pena-Flores; case fact pattern differs	Pena-Flores factors govern and were not satisfied	Pena-Flores factors were not dispositive; exigent circumstances found
Is the search permissible despite the timeline and processing delay	Delay was justified by ongoing investigation and multiple sites	Significant delay negates impracticability of warrant; no urgent need	Courts found overall actions reasonable under totality

State v. Pena-Flores, 198 N.J. 6 (New Jersey 2009) (three elements of automobile exception; exigent circumstances required)
State v. Martin, 87 N.J. 561 (New Jersey 1981) (urgent need to ascertain evidence; vehicle towed for search)
State v. Cooke, 163 N.J. 657 (New Jersey 2000) (state constitution provides greater protections; outlines suppression standard)
State v. Eckel, 185 N.J. 523 (New Jersey 2006) (limits on search incident to arrest in automobile context)
State v. La Porte, 62 N.J. 312 (New Jersey 1973) (early automobile-search standards in NJ)
State v. Colvin, 123 N.J. 428 (New Jersey 1991) (unplanned stop and risk to evidence; exigency assessment)
State v. Johnson, 193 N.J. 528 (New Jersey 2008) (probable cause and exigent circumstances framework)
State v. O'Donnell, 203 N.J. 160 (New Jersey 2010) (totality-of-circumstances approach to reasonableness)