State v. Walker, 213 N.J. 281

Defendant Rashad Walker was subject to undercover drug-buy operations at his Riverview Court public housing apartment after police received a confidential informant tip.
Officers knocked; defendant opened the door while smoking a marijuana cigarette, prompting arrest and police entry into the apartment to prevent flight, destruction of evidence, or other interference.
Inside the living room, officers found cash and in plain view drugs and drug paraphernalia (marijuana, heroin, cocaine) following the entry.
The trial court held probable cause to arrest arose from the door-opening event; the Appellate Division reversed and suppressed the evidence, leading to certification to the Supreme Court of New Jersey.
The State contends the tip plus observed conduct created probable cause and exigent circumstances justifying a warrantless home entry; defendant argues the tip was insufficient and Welsh/Bolte-like limits apply.
The Court ultimately held the warrantless arrest and entry permissible under exigent-circumstances doctrine, enabling recovery of the marijuana cigarette and CDS, with plain-view seizure of additional contraband.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was probable cause for arrest based solely on the informant tip sufficient?	State argues tip reliable due to informant history and detail; corroboration from defendant smoking supports probable cause.	Walker contends tip lacked sufficient basis of knowledge and specificity; smoking alone does not prove CDS possession with intent to distribute.	Tip alone insufficient; combined with observed offense created probable cause.
Did exigent circumstances justify a warrantless entry into the home after probable cause arose?	State asserts exigent circumstances existed to prevent destruction of evidence and to arrest an offender in the act.	Welsh/Bolte principles suggest minor-offense context and lack of immediate danger do not justify entry; police-created exigencies are disfavored.	Exigent circumstances justified limited entry to arrest for a disorderly offense and retrieve the cigarette.
Is the scope of a lawful exigent-entry limited to detaining the suspect and securing evidence, or does it authorize broader search?	Officers could seize the marijuana cigarette and later CDS seen in plain view.	Exigency should not permit a broad search of the apartment beyond preventing destruction of evidence.	Entry was limited and lawful; subsequent plain-view seizure of CDS was permissible.

State v. Keyes, 184 N.J. 541 (2005) (tip reliability and basis of knowledge insufficient for probable cause)
State v. O’Neal, 190 N.J. 601 (2007) (probable cause and exigent-circumstances framework for warrantless entry)
King, 563 U.S. 452 (2011) (knock-and-announce and destruction of evidence during exigent search)
Welsh v. Wisconsin, 466 U.S. 740 (1984) (minor offenses do not justify warrantless home entry absent exigent circumstances)
Bolte, 115 N.J. 579 (1989) (majority rule on exigent circumstances for minor offenses; exception for police-created exigency)
Hutchins, 116 N.J. 457 (1989) (police-created vs. independent exigenes; need for non-police-created exigency)
State v. DeLuca, 168 N.J. 626 (2001) (fact-sensitive approach to exigent circumstances)
State v. Nagy, not applicable (not applicable) (placeholder not cited in opinion)