Warrantless Vehicle Search in Prison Lot Okay – State v. Daniels

Today’s Appellate Division decision in State v. Daniels expands the scope of the special needs exception to the warrant requirement in the context of prison facilities. In this case, a computer screening of a visitor to a prison revealed recent exposure to CDS. A search of the visitor’s person was negative for contraband. However, a subsequent warrantless search of her vehicle in the prison parking lot led to the recovery of a small amount of CDS.

The Court held that the search of the vehicle was reasonable in that prisoners are sometimes permitted to wander in the prison’s parking lot and thus could have ready access to CDS left for them in a motor vehicle.

Download a copy of State v. Daniels

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