My Home is a castle—- Even if it is an abandoned row home that I do not own!

August 20, 2019

An expectation of privacy and “public access” to a common area of a boarded up row home. Submitted by New Jersey Criminal Lawyer, Jeffrey Hark State v. Williams    NJ Appellate Division August 19, 2019 Approved for Publication   Issue: The central issue in this appeal is whether a resident of a boarding or rooming house…

Unlawful Possession of a Handgun | State of New Jersey v. Angel Rivera

June 21, 2019

Superior Court Of New Jersey, State of New Jersey versus ANGEL L.RIVERA Submitted by New Jersey Criminal Lawyer, Jeffrey Hark Angel Rivera was charged with second-degree unlawful possession of a handgun without a permit and second-degree possession of a controlled dangerous substance after the denial of his suppression motion. Defendant was sentenced to five years…

PTI Appeal—- Abuse of Prosecutor’s Discretion when considering factors no longer applicable!

June 2, 2019

State v. Davon M. Johnson New Jersey Supreme Court Argued March 11, 2019 — Decided May 30, 2019 Submitted by New Jersey Criminal Lawyer, Jeffrey Hark. Issue on Appeal:  Johnson’s unsuccessful application for pretrial intervention (PTI).  Johnson was charged with third-degree possession of a controlled dangerous substance (CDS) within 1000 feet of a school zone,…

Illegal “prolong defendant’s roadside detention” and a police dog sniff his vehicle for drugs

May 23, 2019

State v. Rodriguez  New Jersey Appellate Division May 21, 2019 (Not Approved for Publication) Submitted by New Jersey Criminal Layer, Jeffrey Hark Issue: How long can the police keep a motor vehicle driver at a motor vehicle stop for a mere equipment violation? Facts: The following facts are derived from the motion record. On March…

What is Reasonable & Articulable Suspicion mean in New Jersey in the confines of a motor vehicle stop??

May 9, 2019

State v. Nelson, New Jersey Supreme Court Decided May 8, 2019 — Submitted by New Jersey Criminal Lawyer, Jeffrey Hark. We therefore consider whether a reasonable and articulable suspicion beyond that which justified the stop supported the canine sniff. See Dunbar, 229 N.J. at 540 (“[I]f an officer has articulable reasonable suspicion independent from the reason…

NEWS FLASH, NJ Supreme Court Rules: Motor Vehicle stop extended for 40 minutes in order to wait for Drug Sniffing dog deemed acceptable in New Jersey

May 9, 2019

State v. Nelson, New Jersey Supreme Court Decided May 8, 2019  Submitted by New Jersey Criminal Lawyer, Jeffrey Hark. Commentary:  The court rules that a 40 minute wait for a drug sniffing dog to arrive based on relatively flimsy ‘independent reasonable and articulable suspicion” of the detective who conducted a motor vehicle stop was not…

Unlawful Possession for Weapon Protective Sweep by police at scene of Motor Vehicle Stop

May 7, 2019

There must be specific and articulable facts that, at the time of the search of a vehicle, a person is capable of gaining immediate control of a weapon or weapons Submitted by New Jersey Criminal Lawyer, Jeffrey Hark. State v. Ortiz  New Jersey Appellate Division May 6, 2019 (Not Approved for Publication) Facts: The salient…

Standard of review Suppression of Evidence Pre-State v. Witt (Pena-Flores Standard of Review) Motor Vehicle Stop New Jersey

May 7, 2019

State v. Ortiz  New Jersey Appellate Division May 6, 2019 (Not Approved for Publication) Submitted by New Jersey Criminal Lawyer, Jeffrey Hark. In reviewing a motion to suppress evidence, this court must defer to the trial court’s fact findings underlying its decision, “so long as those findings are supported by sufficient credible evidence in the…

State v. James L. Rogers NJ Appellate Division Decided May 3, 2019 (Not Approved for Publication)

May 5, 2019

State v. James L. Rogers Submitted by New Jersey Criminal Lawyer, Jeffrey Hark. Pertinent Facts: The defendant was brought to the police department and advised he will have to submit to the Alcotest. Both at the scene and after he was taken to the police station, defendant was uncooperative and confrontational. On the charge for…

State v. James Rogers Decided May 3, 2019 New Jersey Appellate Division (Not Approved for Publication) Appealing a Municipal Court Conviction — Standard of Review

May 5, 2019

State v. James Rogers Submitted by New Jersey Criminal Lawyer, Jeffrey Hark. An appeal of a municipal court conviction must first be addressed by the Law Division de novo. R. 3:23-8. The role of the Law Division is to make independent findings of facts and conclusions of law based on the record developed in the…