State of New Jersey v. Maurice D. Ross

New Jersey Superior Court Appellate Division·Decided March 4, 2026·No. A-4138-24·Unpublished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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-4138-24

STATE OF NEW JERSEY, Plaintiff-Respondent,

v. MAURICE D. ROSS,

Defendant-Appellant.

Argued February 3, 2026 – Decided March 4, 2026 Before Judges Gooden Brown, Rose and DeAlmeida.

On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Essex County, Indictment Nos. 23-03-0533 and 23-03-0534.

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

Matthew E. Hanley, Assistant Prosecutor, argued the cause for respondent (Theodore N. Stephens, II, Essex County Prosecutor, attorney; Matthew E. Hanley, of counsel and on the brief).

PER CURIAM By leave granted, defendant Maurice D. Ross appeals from a July 1, 2025 Law Division order denying his motion to suppress a .45 caliber handgun seized during a protective frisk conducted by a special law enforcement officer (SLEO)1 on Newark Housing Authority (NHA) property just before midnight, on May 14, 2022. In a written decision accompanying the order, the motion court rejected defendant's argument that the body worn camera (BWC) statutes, N.J.S.A. 40A:14-118.3 to -118.5, read in pari materia with the SLEO Act, N.J.S.A. 40A:14-146.8 to -146.18, and the Attorney General BWC Policy 2 entitled defendant to the mandatory rebuttable presumption – that "exculpatory evidence was destroyed or not captured in [his] favor" under N.J.S.A. 40A:14-

1 SLEOs are also referenced in the record as "special police officers" and "SPOs." 2 In his April 17, 2025 supplemental submission to the motion court, defendant provided Attorney General Directive 2021-5, issued with the May 2021 BWC Policy, and the court cited that version of the BWC policy in its decision. See Off. of the Att'y Gen., Law Enf't Directive No. 2021-5, Directive Revising Policy Regarding Use of Body Worn Cameras (BWCs) and Stored BWC Recordings (May 25, 2021). However, at the time of the incident, Attorney General Directive 2022-1, issued with the January 2022 BWC Policy, was in effect. See Off. of the Att'y Gen., Law Enf't Directive No. 2022-1, Update to Body Worn Camera Policy (Jan. 19, 2022). Accordingly, we cite the applicable sections of the May 2021 BWC Policy as those sections do not differ from the January 2022 BWC Policy. In doing so, we use Attorney General Guidelines and BWC Policy interchangeably.

A-4138-24

118.5(q)(2) – because the SLEO did not activate a BWC at the time of the stop and frisk. The court concluded the handgun at issue was lawfully seized from defendant's waistband.

On appeal, defendant reprises the same arguments raised before the motion court:

POINT I

THE [MOTION] COURT ERRED IN FINDING THAT THE BWC STATUTE DID NOT APPLY TO THE SLEO. THIS COURT SHOULD EITHER ORDER SUPPRESSION OR REMAND FOR ANOTHER HEARING TO APPLY THE BWC STATUTE.

A. SLEOs Are Subject to the Requirements of the BWC Statutes.

B. This Court Should Order Suppression. Or at the Very Least, It Should Remand for a New Suppression Hearing Before a New Judge.

We reject these contentions and affirm.

I.

We summarize the pertinent facts and events from the motion record.

Following his arrest, defendant was charged in two related Essex County indictments with second-degree unlawful possession of a handgun, N.J.S.A.

A-4138-24

2C:39-5(b), and second-degree certain persons not to have weapons, N.J.S.A. 2C:39-7(b)(1). Defendant thereafter filed the present motion. 3 During the two-day testimonial hearing, the State presented the testimony of SLEO Benjamin Mauriello and NHA Assistant Director Michael Grainger. The State also moved into evidence footage of the BWC worn by Officer Santiago4 of the Newark Police Department (NPD), who responded to the scene after defendant was arrested, but did not testify. Defendant did not take the stand or present any evidence.

At the time of the hearing, Mauriello was an SLEO for nearly sixteen years. He explained SLEOs receive the same "full training as any other police officer in the State of New Jersey," but after graduation from the police academy SLEOs must "find [their] own work."

Employed by the NHA since 2018, Mauriello handles "[a]nything that happens criminally on [NHA] property . . . from tickets to domestic violence."

3 In his notice of motion and certification in support of the motion, defense counsel stated police seized a ".45 caliber revolver and [five] .410 gauge shotgun shells." In its decision on the motion, the court found "Mauriello seized a black .45 caliber handgun loaded with [five] .410 caliber shells from [d]efendant." Although there is no information about the shells in the record provided on appeal, seizure of the ammunition is not pertinent to the issues raised before us. 4 Santiago's first name is not included in the record provided on appeal.

A-4138-24

Mauriello testified he was trained by the NPD, which issued his service weapon and radio, but he purchased his own "[u]niforms, body armor, boots, [and] duty rig." Mauriello further stated the NPD did not issue BWCs to SLEOs.

When questioned whether the NPD provided BWC training, Mauriello stated he could not recall the date, but sometime in 2022, 5 the NPD administered "a test" to SLEOs. He said SLEOs "were supposed to get [BWCs], but [they] never got them."

Mauriello testified he purchased his own BWC while working for the Newark Board of Education before he was employed by the NHA. Mauriello continued: "And I purchased my own" because "you're dealing with a lot of kids and stuff like that, so I just wanted to have my own. Before -- it was before [the NPD] even had body cams."

Mauriello stated he has activated his personal BWC during his employment with the NHA, but "not often." He typically activates the BWC when he believes "a situation is going to become hairy." He retains the footage in "important" circumstances, such as "shootings" and "domestic violence []" incidents.

5 Mauriello was not asked whether the training occurred before or after the May 14, 2022 incident date.

A-4138-24

Santiago's BWC footage depicted Mauriello in uniform wearing a BWC at the time of the May 14, 2022 incident. Noting the light on his BWC was not "flickering" in the video footage, Mauriello confirmed he did not activate his BWC during the incident. When asked why he did not do so, Mauriello explained: "Everything happened so fast, I just didn't really think about it, you know."

On cross-examination, Mauriello acknowledged, in his incident report, he did not indicate he was wearing a BWC. But he testified, at the bottom of the report, he noted: "No body worn camera assigned to SPO Mauriello." Mauriello explained, "That's what we -- I do on every report because we are not assigned body cams, so . . . when regular officers are assigned body cams, . . . they put it in [their reports] that it is body cam worn [sic]."

Turning to the circumstances leading to defendant's arrest, Mauriello testified the day before the incident, he and Grainger reported to a vacant NHA complex following "complaints of narcotics sales and trespassing." Mauriello and Grainger performed "verticals," which entailed ascending and descending the stairs "to make sure there's nobody inside the buildings." Upon entering one of the buildings, Mauriello and Grainger "encountered two individuals." "Grainger[] told them to leave, they were trespassing, and they could be

A-4138-24

arrested." Both individuals left the premises and the interaction was not documented.

Free access — add to your briefcase to read the full text and ask questions with AI

State of New Jersey v. Maurice D. Ross, (N.J. Ct. App. 2026).

State of New Jersey v. Maurice D. Ross (State of New Jersey v. Maurice D. Ross) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
Sibron v. New York
392 U.S. 40 (Supreme Court, 1968)
State v. Robinson
974 A.2d 1057 (Supreme Court of New Jersey, 2009)
Frugis v. Bracigliano
827 A.2d 1040 (Supreme Court of New Jersey, 2003)
State v. Thomas
542 A.2d 912 (Supreme Court of New Jersey, 1988)
DiProspero v. Penn
874 A.2d 1039 (Supreme Court of New Jersey, 2005)
State v. Lund
573 A.2d 1376 (Supreme Court of New Jersey, 1990)
State v. Davis
517 A.2d 859 (Supreme Court of New Jersey, 1986)
State v. Stovall
788 A.2d 746 (Supreme Court of New Jersey, 2002)
State v. Valentine
636 A.2d 505 (Supreme Court of New Jersey, 1994)
State v. Bellamy
616 A.2d 1323 (New Jersey Superior Court App Division, 1992)
State v. Elders
927 A.2d 1250 (Supreme Court of New Jersey, 2007)
State of New Jersey v. Ivonne Saavedra
81 A.3d 693 (New Jersey Superior Court App Division, 2013)
State v. Ivonne Saavedra (073793)
117 A.3d 1169 (Supreme Court of New Jersey, 2015)
State v. Terrell Hubbard (073539)
118 A.3d 314 (Supreme Court of New Jersey, 2015)
State v. Marc A. Olivero (073364)
115 A.3d 1270 (Supreme Court of New Jersey, 2015)
Joel S. Lippman, M.D. v. Ethicon, Inc. (073324)
119 A.3d 215 (Supreme Court of New Jersey, 2015)
In Re Declaratory Judgment Actions Filed by Various
141 A.3d 359 (New Jersey Superior Court App Division, 2016)