State of New Jersey v. Rafael Hidalgo

New Jersey Superior Court Appellate Division·Decided July 29, 2026·No. A-3365-24·Unpublished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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3365-24

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

RAFAEL HIDALGO,

Defendant-Appellant. _______________________

Argued June 3, 2026 – Decided July 29, 2026

Before Judges Paganelli and Jacobs.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Indictment No. 23-12-1558.

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

Penelope Mary Way, Assistant Prosecutor, argued the cause for respondent (Wayne Mello, Hudson County Prosecutor, attorney; Penelope Mary Way, of counsel and on the brief).

PER CURIAM Defendant Rafael Hidalgo appeals from a January 13, 2025 order denying

his motion to suppress physical evidence recovered following his arrest and

from the June 16, 2025 judgment of conviction entered following his guilty plea

to unlawful possession of a handgun. We affirm.

I.

On May 9, 2023, the West New York Police Department issued a "Be On

the Lookout" (BOLO) for defendant as a suspect in a vehicle theft. The BOLO

included a photograph of defendant wearing his hair in dreadlocks. Two days

later, a warrant was issued for defendant's arrest. On May 12, police issued an

updated BOLO:

Presently, [defendant] has been subjected to complaint warrant 0912 W 2023 000222.

Law enforcement personnel are urged to exercise caution due to an unverified report from the victim suggesting that [defendant] may be in possession of a handgun. It should be noted that [defendant] has previously faced charges related to the unlawful possession of a firearm.

On May 26, while patrolling near 60th Street and Buchanan Place, Officer

Rigo Mendoza observed an individual riding an electric bicycle whom he

recognized from the BOLO photograph. Officer Mendoza attempted to stop the

suspect by activating his patrol vehicle's lights and sirens and ordering him to

A-3365-24 2 stop. Instead, defendant fled on the bicycle. Officer Mendoza then pursued on

foot for several blocks before losing sight of him. He radioed a description of a

male with dreadlocks, wearing a red hooded sweatshirt, black jeans, a black N95

mask, and riding an electric bicycle.

Other officers apprehended defendant shortly thereafter. By the time of

his arrest, however, defendant was no longer wearing the red hooded sweatshirt.

Surveillance video obtained by police and played at the suppression hearing

showed defendant parking his bicycle in what officers alternately described as

an "alley" or "alleyway." Defendant is seen removing his hoodie, wrapping a

firearm in it, and tossing the hoodie with the firearm onto the roof of a nearby

residential garage. He then exits the frame wearing a white sleeveless T-shirt.

After the arrest, police recovered defendant's bicycle, a fanny pack, two bags

containing a controlled dangerous substance (CDS), and the N95 mask from the

alley. From on top of the garage, police also recovered the hoodie with the

firearm concealed inside, a scale, and a white powdery substance, subsequently

confirmed as a CDS.

A Hudson County grand jury returned an indictment charging defendant

with eleven counts, including second-degree unlawful possession of a handgun,

N.J.S.A. 2C:39-5(b); third-degree possession with intent to distribute CDS in a

A-3365-24 3 school zone, N.J.S.A. 2C:35-7(a); second-degree possession of a handgun while

committing a drug offense, N.J.S.A. 2C:39-4.1(a); and fourth-degree obstructing

administration of law ("by means of flight, by ignoring verbal commands to stop,

and obstructing the detection or investigation of a crime"), N.J.S.A. 2C:29-1(a).

Defendant moved to suppress the physical evidence, arguing the stop and

seizure were unconstitutional because Officer Mendoza lacked reasonable

suspicion to justify the stop and the subsequent pursuit constituted an unlawful

seizure. Judge Carlo Abad conducted a hearing in September 2024 and heard

oral argument in January 2025.

At the suppression hearing, Officer Mendoza testified he was familiar

with the BOLO as it was posted "just [about] a month prior to the incident . . .

[a]nd then every day during lineup we would brush up on it and see it and see

that person of interest." Officer Mendoza estimated he had seen the BOLO more

than ten times, was aware of the active warrant, and recognized the suspect by

his distinctive dreadlocks protruding from his hoodie, despite defendant wearing

a face mask. Officer Mendoza described defendant's flight and testified he

pursued him on foot before losing sight of him as he fled on the bicycle. Officer

Mendoza further testified that after other officers apprehended defendant, he

A-3365-24 4 returned to the scene of the arrest, positively identified defendant, and advised

defendant of the open arrest warrant.

Officer Michael Mendez testified he assisted in canvassing the area after

Officer Mendoza's pursuit, ultimately locating the suspect. He asked a resident

on a neighboring balcony if he had seen "anything red on top of the garages and

he said, 'Yeah. There's something red up there[.]'" Detective Chris Ortiz

testified he served as the lead detective, created the BOLOs, and confirmed the

suspect's identification and open warrant, later documenting the recovery of the

items from the alley, and obtaining surveillance footage showing the suspect

discarding evidence.

Defendant argued Officer Mendoza identified him solely by his

dreadlocks, a feature common to many individuals, and that the BOLO lacked

sufficient detail. Defendant also contended the abandonment of evidence was a

direct result of an unlawful stop, and thus, the evidence should be suppressed as

fruit of the poisonous tree.

The State maintained Officer Mendoza had reasonable suspicion to stop

defendant. The BOLO included a photograph depicting defendant's distinctive

"big dreadlocks," as Officer Mendoza characterized them, which he perceived

"protruding through the hoodie." The State further argued Officer Mendoza was

A-3365-24 5 justified in pursuing defendant, having recognized him and knowing there was

a warrant for his arrest. Defendant's flight added to the reasonable suspicion

and the evidence recovered was voluntarily abandoned during a lawful pursuit.

In a written decision and accompanying order, Judge Abad denied the

motion to suppress. Among his findings, he wrote:

The BOLO, while general in some respects, described . . . [d]efendant's dreadlocks and included a photograph, which Officer Mendoza reasonably relied upon to match the individual he observed. . . . [T]he [c]ourt finds that the combination of the photo and . . . [d]efendant's appearance, behavior, and decision to evade police created sufficient particularized suspicion under the constitutional standard. Importantly, the fact that . . . [d]efendant fled further corroborated Officer Mendoza's suspicion as flight is a relevant factor in assessing reasonable suspicion.

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State of New Jersey v. Rafael Hidalgo, (N.J. Ct. App. 2026).

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