## Facts

- Robert Reldan was indicted in Bergen County, New Jersey, for two homicides: Susan Heynes (abducted Oct. 6, 1975; body found Oct. 27, 1975) and Susan Reeve (abducted Oct. 14, 1975; body found Oct. 28, 1975), both discovered in Rockland County, New York, and determined to have died by strangulation.
- Investigators obtained evidence linking Reldan’s station wagon to the homicides, including dog tracking that detected the victims’ scents in the vehicle and microscopic hair comparison suggesting consistency with the victims’ hair.
- Police executed a facially valid warrant authorizing a search of Reldan’s car for evidence connected to a series of robberies, not the homicides.
- During execution of the robbery warrant, detectives used a vacuum device to collect human hair and other minute particles from the car’s floor area; the material was later analyzed and used as homicide evidence.
- FBI agents assisted during the search and were focused on the homicide investigation.
- In 1979, the trial court suppressed the vacuum-sweep evidence as beyond the warrant’s scope; the first trial ended in a mistrial, and a second trial resulted in murder convictions later reversed on appeal and remanded for a third trial.
- Before the third trial, the State sought reconsideration of the suppression ruling; the trial court again suppressed, but the Appellate Division reversed and held the evidence admissible.

## Issues

1. Whether vacuuming the car’s interior to seize hair and microscopic debris, while executing a warrant for robbery-related evidence, exceeded the warrant’s scope or was unreasonable under the Fourth Amendment and the New Jersey Constitution.
2. Whether FBI participation, given their homicide-focused purpose, rendered the execution of the robbery warrant an improper pretext to gather homicide evidence.
3. Whether the earlier suppression ruling barred reconsideration and appellate review of the evidence’s admissibility after a mistrial, reversal, and remand for retrial.

## Decision

- The Supreme Court of New Jersey affirmed the Appellate Division and held the vacuum-sweep evidence admissible at the third trial.
- The Court concluded that vacuuming the floor area did not exceed the scope of the valid warrant and was a reasonable method of executing it.
- The Court held that FBI participation did not invalidate the search so long as officers stayed within the warrant’s spatial limits and the class of items authorized to be sought and seized.
- The Court held that the prior suppression order did not preclude reconsideration in the procedural posture created by mistrial, subsequent reversal, and remand for retrial.

## Legal Principles

- The scope of a lawful warrant search is defined by the objects authorized to be sought and the places where there is probable cause to believe they may be found; execution methods are judged by overall reasonableness.
- A warrant-authorized search may use collection techniques reasonably suited to locating the described items, including meticulous trace-evidence collection, without the warrant needing to specify the technique.
- When material is lawfully seized during execution of a valid warrant, subsequent forensic or laboratory analysis of that material generally does not constitute a separate search requiring independent justification.
- The subjective investigative interests of participating officers do not invalidate execution of a valid warrant when the search remains within the warrant’s objective constraints.
- In criminal cases lacking final judgment, a prior suppression ruling may be reconsidered after significant procedural developments such as mistrial, appellate reversal, and remand for a new trial.

## Conclusion

The court held that vacuum collection of hair and debris from a vehicle’s interior, conducted while executing a facially valid warrant for robbery evidence, was a reasonable search within the warrant’s scope; FBI assistance did not render the search unconstitutional, and the earlier suppression order could be revisited after mistrial and remand for retrial.


State v. Reldan, 100 N.J. 187 (1985)