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NJ Supreme Court Clarifies Test for Delayed Searches Incident to an Arrest
In State v. Joao C. Torres (A-15-22/086812) (Decided May 4, 2023), the Supreme Court of New Jersey addressed when law enforcement may conduct warrantless searches of a person incident to an arrest. It adopted the two-factor test set forth in State v. Lentz, 463 N.J. Super. 54, 70 (App. Div.