New Jersey v. Goldsmith
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The issue this case presented for the New Jersey Supreme Court's review centered on whether reasonable and articulable suspicion existed when a police officer conducted an investigatory stop of defendant Nazier Goldsmith on a walkway adjacent to a vacant house. Two police officers were on patrol in Camden in what they believed to be a “high- crime area” known for shootings and drug dealing. Based on his training, 20 years of experience, and his belief that the vacant house was used for the sale of drugs and weapons, Officer Joseph Goonan found it suspicious that defendant was on the walkway next to the vacant house and believed defendant was engaged in drug dealing activity. So the officers approached defendant, blocked his path at the end of the walkway, and began questioning him, asking for his name and for an explanation of his presence on that walkway. Defendant was ultimately charged with weapons and drug offenses. Defendant moved to suppress the gun and drugs, arguing that both the stop and frisk were unlawful because they were not based on reasonable suspicion.
The trial court granted the motion, finding the stop lawful but the frisk unlawful. Because the trial court held the frisk to be unlawful, all the seized evidence (the gun, ammunition, drugs, and money) was suppressed as fruit of the poisonous tree. The Appellate Division reversed, finding that based on the totality of the circumstances -- including defendant’s presence in a high-crime area and his behavior and body language -- the officer’s frisk of defendant was objectively reasonable. The Supreme Court found that the information the officers possessed at the time of the stop did not amount to specific and particularized suspicion that defendant was engaged in criminal activity. Therefore, the officers did not have reasonable and articulable suspicion to initiate an investigatory detention of defendant. The Court reversed the Appellate Division’s judgment and reinstated the trial court’s suppression order.
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