State of New Jersey, Plaintiff-Appellant v. William L. Witt, Defendant-Respondent

Summary

The Court held that the automobile-search rule requiring probable cause plus separate exigent circumstances was unsound and unworkable, and restored a state constitutional rule permitting an on-scene warrantless search when probable cause arises from unforeseeable and spontaneous circumstances. It also held that the validity of the traffic stop was not preserved because the defendant did not challenge it in the trial court. Applying the restored rule prospectively, the Court affirmed suppression under the law governing when the search occurred and remanded for consistent proceedings. Justice LaVECCHIA, dissenting, would have retained the prior exigent-circumstances requirement because the State had not shown special justification to depart from precedent.