State of New Jersey v. Thomas Shannon

Summary

The Supreme Court of New Jersey considered whether evidence seized after an arrest based on a judicially vacated warrant, which remained active in a court database due to an administrative error, should be suppressed. An equally divided Court affirmed the Appellate Division judgment suppressing the evidence, with the concurrence rejecting a subjective good-faith exception under State v. Novembrino and the dissent favoring admission where police reasonably relied on the database information.

Holdings

1. An officer's good-faith belief that an arrest warrant is valid cannot make an arrest constitutional when the warrant has been vacated and no probable cause independently supports the arrest.
2. Evidence seized as a result of the unlawful arrest is subject to exclusion under the New Jersey Constitution, without an exception based on the arresting officer's subjective good faith.

Questions Presented

1. Whether an arrest based solely on an arrest warrant that had been judicially vacated, but remained active in a computer database, is constitutionally valid when the arresting officer reasonably and subjectively believed the warrant was valid.
2. Whether the exclusionary rule requires suppression of evidence seized as a result of that arrest when law-enforcement officers were not responsible for the database error.
3. Whether New Jersey recognizes a good-faith exception to the exclusionary rule in these circumstances.

Disposition

affirmed