New Jersey v. Robinson

The issue presented for the Supreme Court’s review was whether the protective sweep exception to the warrant requirement applied to a police officer’s search of a vehicle’s passenger compartment in the wake of a traffic stop. The officer conducted a brief conversation with defendant, who was the driver, and his three passengers; the vehicle’s occupants responded to the officer’s questions with confusing and evasive answers. The officer learned defendant and one passenger had outstanding warrants and were known to carry weapons. He requested backup and was promptly joined by four other officers. The five officers removed the four occupants from the vehicle and frisked them for weapons. They arrested and handcuffed defendant and one passenger and monitored the other passengers outside of the vehicle. None of the four resisted the officers or sought access to the vehicle. The police officer who had conducted the traffic stop then searched the interior of the vehicle. The officer lifted one passenger’s purse to search the seat, recognized that a weapon was contained in the purse, and retrieved a handgun. Charged with the unlawful possession of a handgun, defendant moved to suppress the weapon on the ground that it was the product of an unconstitutional search. The trial court denied the motion to suppress. A divided Appellate Division panel reversed the trial court’s judgment. The Supreme Court concluded that although the circumstances gave rise to a reasonable suspicion that there was a weapon in the vehicle, the five officers’ swift and coordinated action eliminated the risk that any of the four occupants would gain immediate access to the weapon. Accordingly, the protective sweep exception to the warrant requirement did not govern this case. The Court concurred with the Appellate Division majority’s determination that the community-caretaking exception to the warrant requirement was irrelevant. However, because the inevitable discovery exception to the exclusionary rule could be pertinent to this case, the Court remanded for further proceedings. View "New Jersey v. Robinson" on Justia Law