Officers in Elizabeth, NJ surveil a car for two hours, observing 3 hand-to-hand narcotics transactions. They then search the car - without a warrant - revealing cocaine and heroin. The trial court said that the search was improper under State of New Jersey v Kyle Smart. The appellate division REVERSED the trial court, saying that this search was PROPER!

Join Instructor Lt. Joey Sperlazza as he breaks down the key points and takeaways from the State of New Jersey v Jonathan Lightsey.

The full opinion can be read here: https://www.njcourts.gov/system/files/court-opinions/2025/a3780-23.pdf

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As always, the items described in these cases are for information only. Determine how the situation impacts you in your agency and in your state. Follow your state laws, state guidelines, and department policy and address questions to your superiors and legal advisors.