In this archive episode, Dennis explains that opening a locked container or safe does not require an additional warrant. Recorded on 09/17/2017.
New Jersey adopts the federal standard...State of NJ v. Jackson 1993
In conducting the search the police discovered a locked safe, which was seized and opened, revealing incriminating evidence. The court rejected the argument that the scope of the warrant had been exceeded by the opening of a locked safe, concluding that "[t]he locked safe was a likely source for the specified documents and could therefore be opened."
State v. Hansen, 732 P.2d 127, 131 (Utah 1987) (warrant to search premises for drugs permitted search of locked box within, rejecting contention that a separate warrant was required to open the box).
Although article I, ¶ 7 of the New Jersey Constitution may very well afford our citizens greater protection against unreasonable searches and seizures than does the Fourth Amendment (see State v. Hempele, supra, 120 N.J. at 195, 576 A.2d 793 (and cases cited *210 therein)) neither public policy nor New Jersey decisional law compel a result different from that espoused in the federal authorities referenced above. Indeed, although not dispositive, Reldan, supra, 100 N.J. at 195, 495 A.2d 76, suggests an analysis which is both practical and consistent with the foregoing.