On May 19, 2015, the Supreme Court of New Jersey decided State v. Wright. In this case, a landlord discovered drugs in a tenant’s apartment after letting himself in with a plumber to repair a leak. The landlord called the police and the officers entered without a warrant. They found contraband and the defendant was indicted on various drug offenses as well as second-degree possession of a firearm in the course of committing a drug offense, second-degree possession of a firearm for an unlawful purpose, and fourth-degree possession of a prohibited weapon.
The Supreme Court held that the third-party intervention or private search doctrine did not apply to this case and that the police were required to get a warrant in order to search the apartment. Despite the fact that a private individual has searched the area, law enforcement is not exempt from the warrant requirement unless another exemption applies.