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Monday, March 13, 2017

STATE OF NEW JERSEY VS. JULIAN B. HAMLETT A-4399-14T2


STATE OF NEW JERSEY VS. JULIAN B. HAMLETT
          A-4399-14T2
Defendant challenges the seizure of drugs and a handgun from his Galloway Township motel room pursuant to a search warrant based on probable cause issued by an Atlantic City Municipal Court judge. We hold that although the search warrant application failed to comport with the procedures promulgated for the cross-assignment of municipal court judges pursuant to State v. Broom-Smith, 201 N.J. 229 (2010), defendant's constitutional rights were not violated by the procedural deficiency and therefore suppression of the contraband found in defendant's motel room is not warranted.
We further hold that, with respect to a separate warrantless search of the center console of a rental vehicle defendant was driving, the police were authorized to conduct a limited search for credentials after defendant was unable to produce his driver's license or the vehicle's registration, insurance card, and rental agreement.