State v. Jones

In State v. Jones, 143 N.J. 4, 667 A.2d 1043 (1995), defendant was with a companion, Lonzie Collier, when spotted by two police officers on surveillance regarding a matter unrelated to defendant. One of the police officers knew of an outstanding warrant for Collier's arrest, but was unaware of the reason the warrant had been issued: Collier's failure to pay fines assessed for prior convictions. Id. at 8, 667 A.2d 1043. Defendant and Collier recognized the police officers and fled as they approached. The officers pursued the fleeing men to the third floor of a nearby building, where defendant and Collier entered an apartment. The officers tried the door, found it locked, and kicked it in. One of them testified that he immediately observed a table upon which were strewn narcotics paraphernalia and documents relating to the owner of an automobile which, a few days earlier, had been broken into and some of its contents stolen. A crowbar wrapped in a newspaper was also found on the floor. Defendant and Collier were arrested. Ultimately, defendant gave a statement to the police acknowledging his participation with Collier in the earlier incident and furnishing details. After the trial court denied defendant's motion to suppress the evidence obtained at the apartment as well as his oral statement, and granted his motion to sever other counts of first degree robbery, possession of heroin and receiving stolen property, he was convicted of burglary. Viewing the apartment as Collier's residence, the Supreme Court held that "the valid arrest warrant provided a 'limited authority to enter a dwelling' in which Collier lived when there was reasonable grounds to believe he was there." Id. at 15, 667 A.2d 1043. It held further that "police officers acting pursuant to a valid arrest warrant have the right to follow a fleeing suspect into a private residence," id. at 19. And went on to state: In other circumstances a forcible entry to execute an arrest warrant may not be reasonable. . . . For example, if the police are executing a warrant at a suspect's home, rather than on a fleeing suspect that they by chance happen to see on the street, we expect that the police will present the warrant at a proper hour and will knock and announce their presence at the suspect's door. The main test always remains whether the law enforcement officer has acted in an objectively reasonable manner. Jones, supra, 143 N.J. at 19-20, 667 A.2d 1043.