State of New Jersey v. Afi N. Roy

New Jersey Superior Court Appellate Division·Decided August 26, 2026·No. A-3765-23·Unpublished

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION

DOCKET NO. A-3765-23

STATE OF NEW JERSEY, Plaintiff-Respondent,

v.

AFI N. ROY, a/k/a AFI ROY and AFI K. ROY,

Defendant-Appellant.

Argued February 3, 2026 – Decided August 26, 2026 Before Judges Gooden Brown and Rose.

On appeal from the Superior Court of New Jersey, Law Division, Camden County, Indictment No. 23-03-0867.

Alexandra Marek, Assistant Deputy Public Defender, argued the cause for appellant (Jennifer N. Sellitti, Public Defender, attorney; Alexandra Marek, of counsel and on the briefs).

John J. Santoliquido, Deputy Attorney General, argued the cause for respondent (Jennifer Davenport, Acting Attorney General, attorney; John J. Santoliquido, of counsel and on the brief).

PER CURIAM After losing her motion to suppress evidence seized from her home, first without a warrant and then with a warrant, defendant Afi N. Roy entered a negotiated guilty plea to third-degree aggravated assault, and was sentenced to five years' probation. The seized items consisted of firearms and related evidence. The initial warrantless search was conducted after law enforcement officers responded to a call that defendant had left animals unattended at her house. Defendant had been arrested the day before for shooting at an individual in a car and had been confined in the county jail. An animal control officer was dispatched to defendant's home to assist the officers in caring for the unattended animals. The second search was conducted pursuant to a warrant that was obtained in part from information gained from the initial search. The motion to suppress the evidence seized pursuant to the initial warrantless search was granted in part and denied in part. The judge determined the search was justified in part under the emergency-aid doctrine. As for the second warranted search, the judge determined the independent-source doctrine applied.

On appeal, defendant raises the following points for our consideration:

POINT I

THE WARRANTLESS ENTRY INTO THE HOME WAS UNLAWFUL BECAUSE ANIMAL WELFARE

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DOES NOT QUALIFY AS AN EMERGENCY UNDER THE EMERGENCY-AID EXCEPTION. EVEN IF IT DID, POLICE LACKED AN OBJECTIVELY REASONABLE BASIS TO BELIEVE THAT AN EMERGENCY EXISTED THAT REQUIRED POLICE TO PROVIDE IMMEDIATE ASSISTANCE TO THE ANIMALS.

A. An Animal-Related Emergency Does Not Serve As A Valid Basis For The Invocation Of The Emergency-Aid Exception To Justify A Warrantless Search Of A Home.

B. Any Reliance On N.J.S.A. 4:22-17.7 To Conclude Animal-Related Emergencies Qualify Under The Emergency-Aid Exception To The Warrant Requirement Is Misplaced.

C. Even If Animal-Related Emergencies Qualify Under The Emergency-Aid Exception, There Is No Support In The Record That The Police Had An "Objectively Reasonable Basis" To Believe There Was A True Emergency That Justified Warrantless Entry Into The Home.

POINT II

THE FRUITS OF THE SECOND SEARCH MUST BE SUPPRESSED BECAUSE THE STATE FAILED TO PROVE THAT THE POLICE WOULD HAVE SOUGHT A SEARCH WARRANT WITHOUT THE KNOWLEDGE OF THE TAINTED EVIDENCE AND THAT POLICE DID NOT ENGAGE IN FLAGRANT POLICE MISCONDUCT.

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A. The State Failed To Prove By Clear and Convincing Evidence That The Police Would Have Sought A Warrant Independent of The Evidence Discovered During The Warrantless Search, Regardless Of Whether The Initial Entry Into The Home Is Deemed Unlawful.

B. The State Failed To Prove That The Initial, Illegal Entry Into The Home Was Not The Product Of Flagrant Police Misconduct.

POINT III

THE COURT ERRED IN ITS FINDING AND WEIGHING OF AGGRAVATING FACTORS [THREE] AND [SIX] AND FAILED TO MAKE A FINDING FOR MITIGATING FACTOR [SEVEN]

DURING SENTENCING.

We affirm the conviction but reverse the sentence and remand for resentencing.

I.

On March 21, 2023, defendant was charged in a four-count Camden County indictment with second-degree aggravated assault, N.J.S.A. 2C:12- 1(b)(1) (count one); second-degree possession of a weapon for an unlawful purpose, N.J.S.A. 2C:39-4(a)(1) (count two); second-degree unlawful possession of weapons, N.J.S.A. 2C:39-5(b)(1) (count three); and fourth-degree criminal mischief, N.J.S.A. 2C:17-3(a)(1) (count four).

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Defendant moved to suppress the evidence seized from her home during the initial warrantless search and the subsequent search conducted pursuant to a search warrant. During the suppression hearing, the State produced Berlin Borough Police Officer Mark Peiffer as its sole witness and presented the search warrant application and warrant. Portions of Peiffer's body worn camera footage were also admitted at the hearing. We glean these facts from the record.

On January 22, 2023, at approximately 7:50 p.m., the Camden County Metro Police Department responded to a report of an individual with a firearm. The victim, identified as Kyle Richardson, reported that defendant, "his mother [-]in[-]law," had become irate "due to an ongoing family dispute" and "fired one round into [his] vehicle while he was sitting in it." Defendant then left the scene before police arrived. Upon locating defendant's residence in Berlin, Berlin Borough police officers arrested defendant at approximately 1:30 a.m. on January 23, 2023, with the use of a SWAT team that included Officer Peiffer.

At approximately 10:36 a.m. the following day, January 24, 2023, Peiffer along with other Berlin Borough officers responded to the same home on a call from defendant's mother, Josephine Roy, reporting that animals "had been in the

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house for several days with no one to care for them." Josephine1 told the officers there were two cats and one dog in the home but she did not have a key to enter the residence.

Peiffer gained access to the house through an open window. Officers then walked through the house and located one dog in a crate with empty food and water bowls by the front door, one cat in a closed bedroom, one cat in a crate with a litter box in the basement, and four turtles in a tank in the basement. Peiffer located the cat in the bedroom under a long gun case behind the bed's headboard. Inside the case was a shotgun. An animal control officer was dispatched to the house to assist the officers. When the animal control officer arrived, Peiffer showed her the animals in the house. When the animal control officer opened a drawer below the turtle tank looking for supplies, two starter pistols were discovered which Peiffer secured.

After the animals were secured, the officers left the house until a search warrant was obtained. The search warrant application detailed the alleged incident that resulted in defendant's January 23, 2023 arrest, and recounted the discovery of the shotgun and the two starter pistols during the January 24, 2023

1 We use the first name to avoid confusion caused by the common surname and intend no disrespect.

A-3765-23

warrantless search of the house. The application further described a Smith & Wesson Shield 9mm firearm that was registered to defendant but was not found during the warrantless search of the residence. Upon obtaining the search warrant, the officers returned to the house. During the execution of the warrant, the officers located the Smith & Wesson 9mm firearm registered to defendant, as well as additional firearms and magazine rounds.

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