Legal Standard of Review of a Trial Court’s Motion to Suppress | State vs. Wilson

Submitted by New Jersey Criminal Lawyer, Jeffrey Hark

14-2-9404 State v. Winslow, App. Div. (per curiam) (13 pp.)

When reviewing a motion to suppress, we “must uphold the factual findings underlying the trial court’s decision so long as those findings are supported by sufficient credible evidence in the record.” Handy, supra, 206 N.J. at 44 (citation omitted); see also State v. Mann, 203 N.J. 328, 336—37 (2010) (alteration in original) (citation omitted) (“[A]n appellate court must defer to the trial court’s findings that are substantially influenced by [the court’s] opportunity to hear and see the witnesses and to have the feel of the case, which a reviewing court cannot enjoy.”).

When a reviewing court is satisfied that the findings of the trial court could reasonably have been reached on the record, “its task is complete and it should not disturb the result, even though it has the feeling it might have reached a different conclusion were it the trial tribunal.” State v. Johnson, 42 N.J. 146, 162 (1964). The question of whether those judicially-found facts warrant suppression is purely legal and the trial court’s decision to exclude is subject to plenary review. Handy, supra, 206 N.J. at 45 (citing Manalapan Realty, L.P. v. Twp. Comm. of Manalapan, 140 N.J. 366, 378 (1995)).

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