In State v. Williams, the New Jersey Supreme Court affirmed the Appellate Division’s opinion that reversed a trial court’s order denying suppression of certain physical evidence. Police officers knocked on the front door of a boarding house, and the officers’ knocks caused the door to open, as it apparently was not always closed (this seems to be common among doors that police officers knock on). The officers then knocked on the door that led to the defendant’s room. When he opened the door, the officers saw marijuana inside. The Appellate Division held that the defendant had a reasonable expectation of privacy in the boarding house’s common space. As a result, the officers did not see the contraband from a lawful vantage point. And without that lawful vantage point, the plain view exception to the warrant requirement was not triggered.
