On October 14, 2015, the Appellate Division of New Jersey decided the case of State v. Beerle. This case involved a traffic stop that resulted in the defendant being charged with possession of heroin under N.J.S.A. 2C:35-10(a)(1). The defendant argued that there was no probable cause for the stop and that he was stopped by the police for longer than was necessary.
In denying the motion to suppress, the trial court found that the driver was stopped for a broken taillight in violation the maintenance of lamps law (N.J.S.A. 39:3-66). The officer opened the passenger door to question Mr. Beerle and saw contraband inside the car. This led to the driver and Mr. Beerle being placed under arrest for possession of CDS.
The Appellate Division ruled that is was reasonable for the police to stop the car for the taillight violation and for the officer to open the passenger door. Therefore, the Appellate Division upheld the trial court’s denial of Mr. Beerle’s motion to suppress evidence.