## Facts

- A service-station attendant, Ronald Sandlin (18), was robbed and killed at a Lakewood, New Jersey service station on August 7, 1966.
- Reginald McKnight and Charles Holland went to the station intending to commit robbery; McKnight ordered gas and a new tire.
- After Sandlin installed the tire, McKnight struck him with a tire iron; Holland took the cash register; the men placed the unconscious Sandlin in their car.
- Sandlin regained consciousness and pleaded for hospital care; McKnight said they would take him after disposing of the cash register.
- The men drove to a wooded area near McKnight’s residence; Sandlin was forced into the woods and shot by Holland; both men buried the body in a shallow grave.
- They divided money taken from the cash register and from Sandlin’s person and attempted to conceal evidence by removing and washing blood-stained car seats and storing them offsite.
- Shortly before the crime, a police officer observed a green-and-white 1955 Ford at the station; later the station was found unattended with a blood trail and the cash register missing.
- Police linked the Ford to McKnight through traffic-summons records and located it concealed in the woods; using a flashlight from outside the vehicle, officers observed apparent blood evidence, missing rear seating, and a firearm.
- The car was seized and later searched, producing physical evidence introduced at trial; McKnight also made statements to police that he sought to suppress.

## Issues

1. Whether the warrantless seizure and subsequent search of McKnight’s automobile violated the Fourth Amendment or the New Jersey Constitution.
2. Whether McKnight’s statements to law enforcement were involuntary or otherwise inadmissible.
3. Whether asserted evidentiary and procedural errors at trial required reversal of the first-degree murder conviction.

## Decision

- The Supreme Court of New Jersey affirmed the first-degree murder conviction and life sentence.
- The court held the warrantless seizure and search of the automobile were permissible given probable cause and the vehicle’s close connection to the robbery-homicide.
- The court upheld admission of McKnight’s statements, finding the trial court’s voluntariness determination supported by the record.
- The court rejected remaining evidentiary and procedural challenges as insufficient to warrant reversal, individually or cumulatively.

## Legal Principles

- Police may seize an automobile without a warrant when there is probable cause to believe it is evidence or an instrumentality of a serious crime.
- Observations made from outside a vehicle into areas visible through windows, including by flashlight, are not treated as an unlawful search.
- A warrantless search of a lawfully seized vehicle may be reasonable where the vehicle is closely tied to the offense and probable cause supports an evidentiary search, consistent with contemporary automobile-search precedent.
- A defendant’s statements are admissible when the record supports a finding that they were made voluntarily and without coercion sufficient to offend due process.

## Conclusion

The court sustained McKnight’s felony-murder conviction and life sentence, concluding that police lawfully seized and searched a concealed, crime-linked vehicle on probable cause and that McKnight’s statements and related physical evidence were properly admitted, with no trial error requiring reversal.


State v. McKnight, 243 A.2d 240 (N.J. 1968)