## Facts

- On December 9, 1973, around 1:30 a.m., Plainfield police officers Peter Cochin and Robert Robinson received radio dispatches reporting that a car had struck a parked car.
- The dispatches further reported that a white male with long hair got out of the car and ran on foot toward nearby railroad tracks, and that the ignition key was missing from the car.
- Within minutes, the officers saw J.B., a 15-year-old white boy with long hair, several blocks from the accident location and generally in the direction of the tracks.
- J.B. had a bleeding lip, an injured-looking arm, and wet clothing; the officers also noticed that brush along the railroad tracks was wet from earlier rain.
- The officers stopped J.B. and asked him to explain where he had been and how he was injured.
- J.B. gave three inconsistent and implausible accounts of being beaten up and could not provide usable details to confirm any version.
- Officer Cochin conducted a full search of J.B.’s person, testifying that he was looking for the missing ignition key connected to the reported accident.
- During that search, Cochin found two plastic bags of suspected marijuana in J.B.’s jacket pocket and then told J.B. he was under arrest.
- The officers transported J.B. to a hospital, where they conducted a further search and found a third bag of suspected marijuana in one of his socks.
- The State charged J.B. in juvenile court. Although the involved car had been stolen, the officers did not know that fact at the time; they believed they were dealing with a “hit and run” (leaving the scene of an accident).

## Issues

1. Whether the officers had probable cause to arrest J.B. for leaving the scene of the reported accident, based on the dispatches, J.B.’s condition and location, and his inconsistent explanations.
2. Whether a full search of J.B.’s person (and the later hospital search) was valid as a search incident to a lawful arrest, even though the officer searched before formally stating that J.B. was under arrest.
3. Whether the marijuana found during the searches had to be suppressed in the juvenile delinquency proceeding if the searches were not justified.

## Decision

- The court denied J.B.’s motion to suppress.
- The court found that, under the facts known to the officers at the time, they had probable cause to believe J.B. had left the scene of a motor vehicle accident after sustaining injuries.
- Because probable cause existed, the search of J.B.’s person was treated as a lawful search incident to arrest (and the resulting seizure of marijuana was lawful).
- The marijuana seized from J.B.’s jacket pocket and later from his sock was admissible in the delinquency case.

## Legal Principles

- Probable cause may be established by the combined weight of: a matching description from a prompt police report, close time-and-place proximity to the reported event, physical signs consistent with the reported flight or injury, and implausible or inconsistent answers when questioned.
- If probable cause to arrest exists before a search begins, a full search of the suspect’s person may be upheld as incident to arrest even if the officer announces the arrest after the search starts.
- In juvenile proceedings, when officers have probable cause to believe a minor committed an act that would be a criminal offense if committed by an adult, they may treat the minor as a juvenile delinquent for probable-cause and arrest purposes.
- The legality of the search is judged by what the officers reasonably knew at the time; later learning that the car was stolen does not defeat a finding that probable cause existed for the offense the officers were then investigating.

## Conclusion

The court held that the dispatch description, J.B.’s proximity and physical condition, and his conflicting explanations gave police probable cause to arrest him for leaving the scene of an accident, making the ensuing searches permissible as incident to arrest and the marijuana admissible in the juvenile delinquency proceeding.


State in Interest of J.B., 328 A.2d 46 (1974)