State v. Ghaznavi (New Jersey 2020) 2020 N.J. Super. Unpub. LEXIS 2261

Controlled Delivery; Alert as Probable Cause

In an investigation of packages of controlled substances being shipped, a PSD’s positive alert is an especially significant intervening circumstance because it independently established probable cause to believe the package addressed to defendant’s wife at their shared residence contained controlled substances. See Florida v. Royer (1983) 460 U.S. 491, 506 (noting that had police used a trained PSD to sniff the defendant’s luggage, “a positive result would have resulted in his justifiable arrest on probable cause.”).