State v. Nazier D. Goldsmith (085636) (Camden County & Statewide), 277 A.3d 1028

Officers in an unmarked vehicle wearing tactical vests patrolled a vacant house on Holcaine Street in Camden, which they believed (based on officer testimony) was used for open-air drug sales and weapons storage.
Officers observed two men in front of the house who walked away as the officers exited the vehicle; at the same time defendant (Goldsmith) emerged from a narrow walkway beside the vacant house.
Officers approached and, positioned at the end of the walkway, questioned defendant about his presence; the officer later acknowledged the positioning impeded defendant’s forward progress.
Defendant appeared nervous, said his ID was in his jacket pocket, and asked that officers not pat him down; the officer then conducted a frisk, felt and recovered a handgun, and later found drugs and money on defendant and drugs on the walkway.
Trial court suppressed all evidence as fruit of an unlawful frisk (finding the stop lawful but the frisk unlawful). The Appellate Division reversed (upholding the frisk). The New Jersey Supreme Court granted leave and reversed the Appellate Division, holding the initial stop lacked reasonable and articulable suspicion and remanding to reinstate the suppression order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable and articulable suspicion to initiate an investigatory stop when they blocked defendant at the end of the walkway	Officer Goonan’s training/experience + (1) vacant house known for drug sales, (2) two men who walked away, and (3) defendant emerging from the walkway justified suspicion	Presence in a high-crime area and furtive movements are insufficient; officers had only a hunch and relied on generalized, potentially biased characterizations of the neighborhood	No. Court held officers lacked particularized, objective suspicion; the stop was unlawful and evidence must be suppressed
Whether frisk was lawful (officer safety exception)	Even if stopped lawfully, officer observed nervous behavior and suspected recent drug activity, and drug dealers often carry weapons, so a frisk was reasonable	Nervousness and presence in a high-crime area do not alone justify a weapons frisk; defendant never made threatening movements	Not reached on merits—because the stop was unlawful the Court did not decide the frisk; trial court had found frisk unlawful

Terry v. Ohio, 392 U.S. 1 (1968) (establishes standard for investigatory stop and reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (2000) (presence in an area of expected criminal activity, standing alone, is insufficient for reasonable suspicion)
State v. Rosario, 229 N.J. 263 (2017) (defines investigative detention from defendant’s perspective and when an individual is not free to leave)
State v. Chisum, 236 N.J. 530 (2019) (high-crime area is a relevant but non-decisive factor in reasonable-suspicion analysis)
State v. Pineiro, 181 N.J. 13 (2004) (totality-of-the-circumstances inquiry and consideration of officer experience)
State v. Elders, 192 N.J. 224 (2007) (standard of appellate deference to trial-court factual findings)
State v. Nyema, 249 N.J. 509 (2022) (information acquired after a stop cannot retroactively justify the stop)