## Facts

- A Lakewood Township officer stopped a car for speeding in the early morning of July 27, 1997.
- The car displayed a temporary registration tag listing Barbara Edwards as owner.
- The driver gave inconsistent names and could not produce a driver’s license; a computer check showed her license was suspended and revealed two outstanding warrants.
- The officer arrested Edwards on the warrants, handcuffed her, searched her person, and placed her in a patrol car.
- The passenger, Walter Evans, was removed from the car and placed in a backup patrol car.
- The officer then searched the car’s passenger compartment and found a toy handgun and a large knife under the front passenger seat.
- Months later, police linked the toy gun and knife to an armed robbery investigation allegedly involving Evans and John E. Bruns.
- At Bruns’s robbery prosecution, the State sought to introduce the toy gun and knife; Bruns moved to suppress them as the product of an unlawful warrantless vehicle search.

## Issues

1. Whether Bruns, who did not own or occupy the vehicle when it was searched, had standing to challenge the warrantless search and seek suppression of the items seized.

## Decision

- The Supreme Court of New Jersey reversed the Appellate Division’s suppression ruling.
- The court held Bruns lacked standing to move to suppress evidence seized from Edwards’s vehicle.
- Because standing was dispositive, the court did not decide whether the search complied with New Jersey rules governing warrantless automobile searches (including search-incident-to-arrest limits).
- The court reinstated Bruns’s armed robbery conviction.

## Legal Principles

- A defendant seeking suppression must establish a personal, reasonable expectation of privacy in the place searched or the item seized; incrimination from the seized evidence alone is insufficient.
- Standing is a threshold inquiry; a defendant generally may not vicariously assert another person’s privacy rights in a vehicle or other property.
- When a defendant lacks standing, courts need not reach the legality of the challenged search under warrant exceptions.

## Conclusion

The court ruled that Bruns could not suppress the toy handgun and knife because he failed to show a personal privacy interest in Edwards’s vehicle or the area searched, making standing absent and leaving the warrantless-search question unresolved for purposes of his case.


State v. Bruns, 796 A.2d 226 (N.J. 2002)