State v. William L. Witt(074468)
126 A.3d 850
| N.J. | 2015Background
- Witt was charged with unlawful possession of a firearm and possession by a convicted person after a patrol stop led to a handgun discovery during a vehicle search.
- Witt moved to suppress arguing the vehicle search violated the New Jersey Constitution under Pena-Flores; the stop itself was not challenged.
- Appellate Division affirmed suppression, ruling Pena-Flores was unworkable and did not justify a warrantless search.
- The Supreme Court granted review to reconsider the automobile-search standard and continuity with Alston, Cooke, and Pena-Flores.
- The Court ultimately overruled Pena-Flores and Cooke, returning to the Alston framework and limiting the automobile exception to on-scene searches based on probable cause, with warrants required when a vehicle is towed or impounded.
- Decision applies prospectively, affirming the Appellate Division’s suppression in this case and remanding for proceedings consistent with the new rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pena-Flores and Cooke should be overruled. | Witt argues Pena-Flores is sound; the State contends it is workable and should be retained. | Witt contends Pena-Flores/Cooke are unsound and unworkable; return to Alston is warranted. | Yes; abandon Pena-Flores/Cooke and adopt Alston-based standard. |
| Scope of the automobile exception under New Jersey Constitution. | Witt contends the UNFORESEEABILITY/SPONTANEITY approach remains valid. | Witt argues for a broader federal-style rule without special state-exigency analysis. | Automobile searches require on-scene exigency; impounded vehicles require warrants absent exigency. |
| Whether the decision should be prospective only. | Witt argues retroactive application would preserve settled law. | The change should apply to future cases to prevent continued misapplication. | Yes; ruling applies prospectively. |
| Whether there is special justification for departing from Pena-Flores. | State bears burden to show practical unworkability. | State failed to prove special justification; data is inconclusive. | Special justification not shown; Pena-Flores overruled for doctrine of stare decisis. |
Key Cases Cited
- State v. Alston, 88 N.J. 211 (1981) (established the original automobile-exception standard with unforeseeability/spontaneity)
- State v. Cooke, 163 N.J. 657 (2000) (adopted exigent-circumstances requirement under state constitution; departed from Alston)
- State v. Pena-Flores, 198 N.J. 6 (2009) (reaffirmed Pena-Flores exigency-based framework and encouraged telephonic warrants)
- Carroll v. United States, 267 U.S. 132 (1925) (origin of automobile exception based on vehicle mobility)
- Chambers v. Maroney, 399 U.S. 1 (1970) (car search efficiency and mobility as a justification for warrantless search)
- Maryland v. Dyson, 527 U.S. 465 (1999) (federal automobile exception does not require separate exigency finding)
- Laboron, Labron v. United States (1996) (vehicle search permitted with probable cause; no extra exigency requirement)
- LaPorte, 62 N.J. 312 (1973) (early NJ cases recognizing exigency and mobility in automobile searches)
- State v. Colvin, 123 N.J. 428 (1991) (exigency-focused analysis within automobile exception)