State v. Curtis L. Gartrell

CourtSupreme Court of New Jersey
DecidedJanuary 17, 2024
DocketA-31-22
StatusPublished

This text of State v. Curtis L. Gartrell (State v. Curtis L. Gartrell) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Curtis L. Gartrell, (N.J. 2024).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

State v. Curtis L. Gartrell (A-31-22) (087597)

Argued September 11, 2023 -- Decided January 17, 2024

SOLOMON, J., writing for the Court.

In this appeal, the Court considers whether defendant Curtis Gartrell, who fled from police outside of Newark Penn Station -- leaving behind a suitcase containing handguns, ammunition, illegal narcotics, and cash -- abandoned the suitcase and is therefore without standing to challenge law enforcement’s warrantless search of the bag.

During the evening of November 6, 2019, an individual at Newark Penn Station reported to New Jersey Transit Police Officers that he had been punched by defendant. As officers spoke to defendant, there was a blue rolling suitcase near him. The officers ran a search for outstanding warrants against defendant. While waiting for the results of the record check, defendant had several phone conversations with a person he referred to as “Spoon” and “bro,” who defendant claimed was coming to pick him up.

Meanwhile, the results of the record check revealed an active warrant for defendant. Officers informed defendant of the warrant and advised him that they intended to place him under arrest. Defendant asked the officers whether he could first give his luggage -- the blue suitcase -- to “Spoon,” but they declined the request, stating they would first take defendant into custody. Defendant called out, “‘Spoon,’ will you get my clothes, bro,” and turned as if preparing to be handcuffed; he then fled from the officers on foot, leaving the blue suitcase unattended on the sidewalk. Officers apprehended defendant after a brief foot chase.

While other officers chased and arrested defendant, one officer secured and searched the suitcase at the entrance of the station, revealing the contraband. Defendant was charged with possessory offenses and resisting arrest.

Defendant filed a motion to suppress evidence recovered from the warrantless search of the suitcase. The trial court granted the motion, reasoning that defendant did not flee police because he wanted to discard the suitcase or relinquish his interest in it. The trial court also rejected the State’s argument that the search

1 incident to arrest exception applied. The State appealed, and the Appellate Division reversed, holding that defendant had abandoned the suitcase. The Court granted leave to appeal. 253 N.J. 279 (2023).

HELD: Defendant’s possessory or ownership interest in the suitcase ceased when he fled police outside Penn Station and deliberately left his suitcase behind in a public place with no evidence of anyone else’s interest in the bag. Because the State has demonstrated by a preponderance of the evidence that the suitcase was abandoned, defendant is without standing to challenge its seizure and search.

1. When property is abandoned, a defendant has “no right to challenge the search or seizure of that property.” State v. Johnson, 193 N.J. 528, 548 (2008). Property is abandoned only if “(1) a person has either actual or constructive control or dominion over property; (2) he knowingly and voluntarily relinquishes any possessory or ownership interest in the property; and (3) there are no other apparent or known owners of the property.” State v. Carvajal, 202 N.J. 214, 225 (2010). The State bears the burden of proving that property was abandoned by a preponderance of the evidence. In Johnson, the Court held that the defendant had not surrendered his standing to challenge the search of a bag solely because he had disclaimed ownership, given that the bag was in an apartment with five occupants and could have belonged to any one of them. 193 N.J. at 549-50. The Court observed that “the police might still have easily determined its owner.” Id. at 550. In Carvajal, the Court upheld the search of an unattended bag left on a bus. 202 N.J. at 218, 230. There, the bag was abandoned because it was “left in a public place or on a public carrier” with “no apparent owner,” and the “police did not search the bag until all apparent owners had disclaimed any possessory interest in the property.” Id. at 225- 26, 229-30. (pp. 11-14)

2. Here, no one disputes that defendant fled police to avoid a lawful arrest, knowing that “Spoon,” if such a person existed -- the Court notes that the defense was unable to confirm “Spoon’s” identity -- did not yet have possession of the suitcase. The act of fleeing to avoid a lawful arrest in a public place demonstrates defendant’s intent to place as much distance as possible between himself and the property left behind. When defendant ran from police in the heavily trafficked area on the sidewalk outside of Penn Station, without any indication that he intended to return, he abandoned the suitcase in a public place. And, unlike when there are a finite and fixed number of potential owners as in Carvajal and Johnson, the police cannot be expected to identify and canvass everyone at or near a major transportation hub to determine who, if anyone, might have a possessory interest in a bag deliberately left behind in a public place. Having thus concluded that the suitcase was abandoned and defendant is without standing to challenge its seizure and search, the Court does not reach the issue of whether police conducted a constitutionally valid search incident to arrest. (pp. 15-17) 2 AFFIRMED and REMANDED to the trial court.

JUSTICE NORIEGA, dissenting, writes that the majority expands the previously narrow abandonment exception to New Jersey’s automatic standing rule by making abandonment synonymous with flight. In Justice Noriega’s view, it is a step backwards in New Jersey jurisprudence to announce a rule that mere flight, without more, ends a defendant’s constitutional right to challenge a search where, as here, the defendant’s actions, words, and behavior all demonstrated his control of and possessory interest in the subject luggage before fleeing. Justice Noriega explains that the police proceeded with the warrantless search here under the theory of “search incident to arrest” and that the theory of abandonment now used to approve that search arose only during litigation. Justice Noriega expresses concern that the majority’s holding stretches the concept of abandonment into an exception to the warrant requirement, rather than a pure issue of standing, and notes that the police in this case could have permissibly conducted an orderly inventory search.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, PIERRE-LOUIS, WAINER APTER, and FASCIALE join in JUSTICE SOLOMON’s opinion. JUSTICE NORIEGA filed a dissent.

3 SUPREME COURT OF NEW JERSEY A-31 September Term 2022 087597

State of New Jersey,

Plaintiff-Respondent,

v.

Curtis L. Gartrell,

Defendant-Appellant.

On appeal from the Superior Court, Appellate Division.

Argued Decided September 11, 2023 January 17, 2024

Peter T. Blum, Assistant Deputy Public Defender, argued the cause for appellant (Joseph E. Krakora, Public Defender, attorney; Alison Perrone, Assistant Public Defender, of counsel and on the briefs).

Frank J. Ducoat, Special Deputy Attorney General/Acting Assistant Prosecutor, argued the cause for respondent (Theodore N. Stephens, II, Acting Essex County Prosecutor, attorney; Frank J. Ducoat, of counsel and on the briefs).

Alexander Shalom argued the cause for amicus curiae American Civil Liberties Union of New Jersey (American Civil Liberties Union of New Jersey Foundation, attorneys; Alexander Shalom, Molly K.C. Linhorst, and Jeanne LoCicero, on the brief).

1 William P.

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Bluebook (online)
State v. Curtis L. Gartrell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-curtis-l-gartrell-nj-2024.