State v. Andrew J. Fede
In March, the Supreme Court of New Jersey clarified what it means to obstruct justice under the New Jersey Criminal Statute 2C:29-1(a). In March of 2014, police officers were dispatched to a report of domestic violence. Patrol officers knocked on the door of defendant’s apartment. Defendant answered the door but only partially opened it, keeping the chain-lock locked.
The officers identified themselves. They told him that they were investigating a domestic violence report. They asked if they could enter his home to check on the well-being of residents of the home. The defendant said that the woman that he lives with was in South Carolina and was not home. He said he was alone in the apartment.
The defendant would not allow officers to enter his apartment since they did not have a warrant. The officers tried to explain that they were permitted to enter his home under the community-care-taking doctrine but the defendant would not allow the officers inside without a warrant. Officers then decided to break the chain-lock to execute a wellness check. They found no one else inside. Thereafter, officers arrested the defendant for obstruction of the administration of justice.
The Supreme Court held that, while officers were permitted to enter the home without a warrant under the community caretaking doctrine, the defendant’s conduct did not amount to obstruction of justice. The criminal statute requires that a defendant make an affirmative action in obstructing justice. Refusing to unlock a chain-locked door does not amount to an affirmative action sufficient to constitute obstruction under the criminal statute. Accordingly, the Supreme Court of New Jersey reversed the decision of the Appellate Division and vacated the defendant’s conviction.
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