The New Jersey Superior Court Appellate Division recently upheld a decision to suppress evidence in a driving under the influence (DUI) case involving Alexander P. Alleyne. This ruling affects how police can conduct DUI investigations and what evidence can be used in court. The decision emphasizes the need for reasonable suspicion before police can escalate their interactions with drivers.

The case, State of New Jersey v. Alexander P. Alleyne, was decided on October 28, 2026, under docket number A-2678-25. The court ruled on an appeal from the State of New Jersey, which sought to overturn a lower court's decision that granted Alleyne's motion to suppress evidence obtained during his arrest. The evidence in question included a handgun and alcohol found in his vehicle after he was pulled over.

Background

The dispute began on January 7, 2024, when New Jersey State Police Trooper Kevin Fowler found Alleyne sleeping in his car on the shoulder of Interstate 78. The vehicle had its hazard lights flashing, and a tow truck was present to assist. Trooper Fowler approached the vehicle and attempted to wake Alleyne, who was initially unresponsive. After several attempts, Fowler managed to wake him and began asking questions.

During the interaction, Alleyne admitted to having a flat tire and stated he was waiting for his son. However, his responses became incoherent, and he failed to provide clear answers to the trooper's questions. Trooper Fowler suspected that Alleyne might be under the influence of alcohol based on his behavior and the loud music coming from the vehicle. After administering field sobriety tests, which Alleyne failed, the troopers conducted a search of the vehicle, leading to the discovery of a handgun and alcohol.

The Ruling

The court ruled to uphold the suppression of the evidence, stating that the troopers did not have reasonable suspicion to conduct the field sobriety tests. The judges noted that while Trooper Fowler's initial actions were justified under the community caretaking doctrine, the subsequent steps taken to investigate DUI were not supported by sufficient evidence.

The court stated, "The record lacks Fourth Amendment-compliant reasonable and articulable suspicion of intoxication to proceed with FST of defendant."

The judges emphasized that the trooper's observations, such as the smell of alcohol and slurred speech, were not corroborated by the body-worn camera footage, which showed Alleyne becoming more responsive as the interaction progressed. The court found that the trooper's testimony was inconsistent with the video evidence, leading to the conclusion that the evidence obtained during the search should be suppressed.

Impact

This ruling has significant implications for future DUI investigations in New Jersey. It reinforces the requirement that police must have reasonable suspicion before conducting field sobriety tests. The court's decision highlights the importance of credible evidence and the need for law enforcement to adhere to constitutional standards when interacting with citizens.

Furthermore, the ruling serves as a reminder that even in situations where officers are performing community caretaking functions, they must not overstep their authority without sufficient justification. This case may influence how similar cases are handled in the future, particularly regarding the admissibility of evidence obtained during DUI stops.

What's Next

The State of New Jersey has the option to appeal this ruling to a higher court, although details regarding any potential appeal were not available in the court filing. There are no related cases pending that were mentioned in the opinion.