Trooper’s Search of Overturned Vehicle Was Illegal

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On August 3, 2015, the New Jersey Supreme Court decided State v. Keaton. In this case, a State Trooper responded to the scene of an accident where the defendant’s car was overturned.

Since the defendant was receiving medical attention, the Trooper entered the overturned car to look for the defendant’s insurance and registration instead of asking the defendant to produce the documents.

Once he was inside the car, the Trooper found an illegal gun and marijuana. The trial court denied the defendant’s motion to suppress the evidence and the defendant pleaded guilty.

He appealed the trial court’s decision to the New Jersey Appellate Division. The Appellate Division ruled that the search of the car was a violation of the Fourth Amendment and reversed the trial court’s decision.

The New Jersey Supreme Court agreed with the Appellate Division and held that the trooper’s decision to enter the car without asking the defendant first was unlawful.