The case arises from a 5:02 a.m. house fire at Paul Caneiro’s home in November 2018. While firefighters were still battling an active blaze in the main structure, police entered the attached garage and seized a security system DVR without a warrant, about forty minutes after first arrival and roughly thirty minutes after the small garage fire had been extinguished. The State alleges the DVR captured Caneiro disconnecting the security cameras before starting the fire. Later, the defendant gave valid consent to search the DVR’s contents. The trial court suppressed the DVR, stressing that the garage fire had been out for nearly thirty minutes and characterizing the officers’ retrieval as calm and deliberate. The Appellate Division affirmed.
The Supreme Court unanimously reversed, holding that under the totality of circumstances, the warrantless seizure was objectively reasonable because time was of the essence and securing a warrant was impracticable while the fire remained active and suppression efforts threatened the integrity of sensitive digital evidence. The Court looked at the whole scene, not just the garage in isolation, and rejected the idea that officers’ calm demeanor meant there was no real emergency. The question, it emphasized, is not how things look in a quiet courtroom years later, but what a reasonable officer on that chaotic scene could conclude at the time.
A big part of the opinion is the Court’s application of the Manning factors, which remain the practical roadmap for exigency in New Jersey: seriousness of the offense, urgency, time needed for a warrant, threat of destruction/loss or danger, whether the suspect is armed, and the strength of probable cause as to the item to be seized. The Court had little trouble finding the first factor favored the State (aggravated arson), and it pointed to the on-scene realities driving urgency: the home was “engulfed in flames,” an officer credibly worried because the fire was near the gas meter and could spread, and ongoing suppression efforts (water, extinguishers, power tools) risked damaging sensitive digital evidence inside the DVR. On timing, the Court found it objectively reasonable to believe there was insufficient time to secure a warrant, especially around 5:30 a.m., given how quickly the fire had spread and how hard it is to predict the time to obtain judicial authorization in that moment. It also credited the record showing police removed only the evidence they believed would be irretrievably destroyed if conditions worsened, and it highlighted probable-cause indicators supporting seizure of the DVR (including a burnt plastic gas can, wet boot prints, burn marks, the smell of gasoline, multiple ignition points, and the officer’s prior knowledge that the security cameras would likely capture the cause of the incident).
For defense attorneys, the takeaway is not that a fire automatically opens the door to a warrant exception; it’s that courts will credit a fast-moving environment where evidence is genuinely vulnerable and officers can explain, with concrete facts, why delay was unreasonable. For prosecutors and law enforcement, the opinion reads like a checklist for litigating exigency correctly: tie the claim to what was known in real time, spell out why the clock mattered, and connect the emergency conditions to the specific evidence at risk. In short, when courts review a seizure without a warrant during an unfolding crisis, they will not freeze-frame the scene after the fact; they will ask whether an objectively reasonable officer, facing the same volatile conditions, could conclude that waiting for a warrant meant losing the evidence.