Full Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0045-25 STATE OF NEW JERSEY, Plaintiff-Respondent, v. RAHMEEN PRATT, a/k/a RAHEEM PRATT, Defendant-Appellant. _______________________ Submitted September 21, 2026 – Decided October 23, 2026 Before Judges Berdote Byrne and Torregrossa- O'Connor. On appeal from the Superior Court of New Jersey, Law Division, Camden County, Indictment No. 24-07-1625. Jordan G. Zeitz, attorney for appellant. Grace C. MacAulay, Camden County Prosecutor, attorney for respondent (Kevin Jay Hein, Assistant Prosecutor, of counsel and on the brief). PER CURIAM In early 2024, Camden County police conducted an investigation into defendant Rahmeen Pratt's suspected drug dealing in the city of Camden later culminating in the execution of a no-knock search warrant and seizure of evidence from various locations, including his residence, resulting in defendant's arrest. 1 After unsuccessfully moving to suppress evidence obtained from the search, defendant entered a conditional guilty plea to second-degree possession with intent to distribute CDS, N.J.S.A. 2C:35-5(a)(1), (b)(2), and second-degree certain persons not to possess firearms, N.J.S.A. 2C:39-7(b)(1), and was sentenced to an aggregate term of nine years' imprisonment with five years of parole ineligibility. Defendant now appeals, seeking to vacate his conviction by challenging the motion court's April 23, 2025 order denying his motion to suppress the 1 An indictment followed charging defendant with two counts of third-degree possession of a controlled dangerous substance (CDS), N.J.S.A. 2C:35-10(a)(1), two counts of possession with intent to distribute CDS, in the first and third degrees, N.J.S.A. 2C:35-5(a)(1), (b)(1), (2), (5), two counts of third-degree possession with intent to distribute CDS in a school zone, N.J.S.A. 2C:35-7(a), two counts of second-degree possession with intent to distribute near certain public property, N.J.S.A. 2C:35-5, N.J.S.A. 2C:35-7.1(a), one count of first- degree maintaining or operating a CDS production facility, N.J.S.A. 2C:35-4, three counts of second-degree weapons possession during a CDS offense, N.J.S.A. 2C:39-4.1(a), one count of third-degree possession of a firearm without a serial number, N.J.S.A. 2C:39-3(n), one count of fourth-degree possession of a large capacity ammunition magazine, N.J.S.A. 2C:39-3(j), and one count of second-degree certain persons not to have weapons, N.J.S.A. 2C:39-7(b)(1). A-0045-25 2 evidence seized from his residence pursuant to the no-knock warrant. He argues the affidavit submitted in support of the warrant application did not establish probable cause to search the residence because it failed to demonstrate a nexus between the criminal activity and the premises, and rested in part, on information from allegedly unreliable informants. He also argues the affidavit failed to set forth the requisite justification for the no-knock order. Having reviewed the record in light of applicable legal principles, we affirm. I. A. We derive the following facts from the sworn warrant affidavit of Camden County Police Detective Nicholas Palermo, who was "responsible for the investigation," and from the motion record. Specifically, in his sworn affidavit, Detective Palermo, a detective with the Camden County Narcotics Gang Unit since 2020 assigned to "the Philadelphia/Camden High Intensity Drug Trafficking Area," with extensive experience and training in narcotics investigations, represented the following. In February and March of 2024, Camden County police "received information regarding a male operating a gray Chrysler 300" and "supplying large amounts of narcotics throughout the city of Camden." The Chrysler was A-0045-25 3 registered to an individual, incarcerated at the time, who had been the subject of prior drug investigations. Police located the Chrysler parked in front of a specific residence on Collings Road and observed a man, later identified as defendant, exit the premises and enter the car. Police identified defendant from an official database, as defendant had two prior criminal convictions, the first for aggravated manslaughter in 1998, N.J.S.A. 2C:11-4(a)(1), and the second for possession of a handgun in 2021, N.J.S.A. 2C:39-5(b)(1). A "confidential source" also identified defendant as the Chrysler's operator and the person "supplying narcotics throughout the city." The Collings Road residence is a single two-story red brick row home with three concrete steps leading to the front door. Near the front door, police observed a camera pointed at the front steps. Police conducted ongoing surveillance. During the week of March 22, 2024, police were in the area of a specific location on Baring Street 2 when they observed a man wearing all black in front of that house engaging in what appeared to be hand-to-hand transactions with pedestrians who approached and exchanged money for "small unknown items." Police then observed the 2 Police later executed a search warrant at this address and seized evidence including large quantities of CDS. Defendant did not challenge the authorization of that search or seek to suppress that evidence. A-0045-25 4 Chrysler drive up and park outside the Baring Street residence. An unknown woman exited a red Dodge Challenger, also parked in the area, and entered the Chrysler. After some time, the woman re-entered the Challenger. The man in black, who was suspected of selling drugs, then entered the Challenger and exited with a bag before entering and exiting the Baring Street property and resuming hand-to-hand transactions. The Chrysler then left the area, and detectives, based on their training and experience, suspected defendant had "resupplied" the Baring Street "drug set." Upon these observations, police enlisted the assistance of a confidential informant, proven reliable to them in the past and whose assistance "resulted in narcotics-related arrests," to make a "controlled buy" at the Baring Street location. Police first searched and provided the informant with money. They then observed the informant approach and make the purchase from the man in black. Upon the informant's immediate return, police collected what appeared to be, again based on the detective's training and experience, crack cocaine and vials of heroin commensurate with the amount of money provided. As surveillance continued at Collings Road that week, police attempted to follow defendant on one occasion after he exited the home, entered the Chrysler, and drove away. Detectives followed, but defendant made several quick turns A-0045-25 5 in a row, sporadically accelerating and varying his speed. This suggested to police defendant was attempting to evade detection, causing them to terminate the pursuit. Three hours later they observed defendant return to Collings Road, enter and exit the residence, and drive the Chrysler to a location where he parked and met with a man wearing a "black bubble jacket." Police observed the man in the bubble jacket reach "into the passenger side" of the Chrysler before quickly walking away toward a nearby apartment building. Approximately thirty minutes later, after defendant left the area, police watched the man in the bubble jacket conducting suspected hand-to-hand drug transactions outside the apartment building. Detectives believed that defendant resupplied the seller with drugs from the Collings Road residence, as defendant made no other stops after leaving his home. Police again organized a controlled buy at that location, this time with a different, though also previously proven reliable, confidential informant, who had assisted in providing useful information that led to narcotics arrests. Following the same procedure of supplying the money, surveilling the purchase, and then retrieving the drugs, detectives observed this informant buy suspected "crack cocaine and heroin" from the man in the black bubble jacket. A-0045-25 6 In April, detectives installed a court-approved GPS tracker on the Chrysler and documented defendant's regular presence at the Collings Road residence, consistent with their physical observations. A confidential informant also advised police defendant had been in possession of a firearm on several occasions. Later that month, detectives observed defendant leave his residence, enter the Chrysler, and drive to a specific location. There, the driver of a red Ford Fusion parked next to the Chrysler and engaged with defendant. Afterward, the driver of the Ford proceeded to Baring Street. Police followed, and there they observed the Ford's driver commence engaging in hand-to-hand transactions indicative of drug sales. Once again utilizing the reliable informant who had made the previous controlled buy at the Baring Street location, police followed the same protocol, and the informant purchased suspected crack cocaine, which the informant turned over to police. Asserting probable cause to believe evidence related to the offenses of possession of CDS and possession with intent to distribute CDS would be found in the premises at Collings Road and Baring Street, as well as in the Chrysler, police sought and obtained a warrant for those locations. The affidavit requested no-knock authorization for the Collings Road residence. It cited defendant's A-0045-25 7 prior convictions, including the 2021 firearms offense, the informant's report of seeing defendant in possession of a gun several times, and the presence of a surveillance camera pointed at the steps as a basis to suspect defendant "could possibly arm himself . . . [and] pose grave danger to officers and any others who may be at or near this location" if police knocked and announced their arrival. The warrant judge issued the search warrant for all three locations and the no-knock authorization for Collings Road. On May 10, 2024, police executed the warrant at the Collings Road residence, where defendant, a woman, and two children were present. Police seized guns, ammunition, roughly 20 ounces and 150 capsules of cocaine, drug paraphernalia, over 100 oxycodone pills, and over $2,000. B. After his indictment, defendant moved to suppress the evidence seized from the Collings Road residence, arguing: (1) Detective Palermo's affidavit was unreliable as the detective was trained in a since-denounced "street crime" program and failed to properly document the investigation via reports, photographs, or lab analysis; (2) the informants were unreliable; (3) critical information was lacking, including any remaining GPS information and locations to which the Chrysler travelled, and any mention of police observing A-0045-25 8 defendant carrying a bag from the home or transferring one in or out of the Chrysler; (4) the affidavit demonstrated defendant was not present at the time of the controlled buys; (5) there was insufficient information demonstrating a nexus between Collings Road and the criminal activity; and (6) the affidavit did not support the issuance of a no-knock warrant. After oral argument, the motion court denied the motion to suppress and found there was probable cause to search the residence at Collings Road. Detailing the investigation and controlling law, the court determined the "observations of the officers, the officers' experience, . . . the information from the confidential source, and looking at the totality of the circumstances," demonstrated a sufficient "nexus" to establish probable cause. It noted defendant frequented Collings Road before engaging with several individuals who subsequently engaged in drug sales after an informant reported defendant was "supplying drugs to drug sets in Camden." The court distinguished State v. Boone, 232 N.J. 417 (2017), finding Boone concerned a search warrant issued for a home without information demonstrating that the defendant lived at the address to be searched. By contrast, it found sufficient evidence here, including police observations and GPS data, connecting defendant to the residence. A-0045-25 9 Citing the correct standard for no-knock orders, the motion court found the affidavit also justified the no-knock feature in this case. The court cited defendant's prior criminal history, noting the "violent nature of the first crime and the involvement of a firearm in the second crime [were] sufficient to justify additional protective measures on the part of police," adding that a confidential informant reported seeing defendant with firearms. Defendant now appeals and argues: POINT I THE LAW DIVISION SHOULD HAVE SUPPRESSED THE EVIDENCE SEIZED FROM [THE COLLINGS ROAD ADDRESS] BECAUSE THERE WAS NO NEXUS SET FORTH IN THE SEARCH WARRANT AFFIDAVIT JUSTIFYING THE SEARCH OF THIS HOME. POINT II THE LAW DIVISION SHOULD HAVE SUPPRESSED THE EVIDENCE SEIZED FROM [THE COLLINGS ROAD ADDRESS] BECAUSE THE SEARCH WARRANT AFFIDAVIT WAS BASED IN-PART ON INFORMATION PROVIDED BY UNRELIABLE SOURCES. POINT III THE LAW DIVISION SHOULD HAVE SUPPRESSED THE EVIDENCE SEIZED FROM [THE COLLINGS ROAD ADDRESS] BECAUSE THE SEARCH WARRANT AFFIDAVIT'S "NO[- A-0045-25 10 ]KNOCK" REQUEST WAS NOT BASED ON A REASONABLE SUSPICION. II. Our review of the trial court's ruling on a motion to suppress evidence is limited. State v. Ahmad, 246 N.J. 592, 609 (2021). We "must defer to the factual findings of the trial court on a motion to suppress so long as its findings are supported by sufficient credible evidence in the record." State v. Erazo, 254 N.J. 277, 297 (2023). "The governing principle, then, is that '[a] trial court's findings should be disturbed only if they are so clearly mistaken that the interests of justice demand intervention and correction.'" State v. Nelson, 237 N.J. 540, 551-52 (2019) (alteration in original) (quoting State v. Robinson, 200 N.J. 1, 15 (2009)). By contrast, we review de novo "a trial court's interpretation of the law" and the legal "consequences that flow from established facts." State v. Gamble, 218 N.J. 412, 425 (2014). Pertinent here, our scope of review of a search warrant is limited. State v. Chippero, 201 N.J. 14, 32 (2009). Critically, a judicially issued search warrant is shrouded in the presumption of validity. State v. Jones, 179 N.J. 377, 388 (2004). "The defendant has the burden of proving the invalidity of the search made pursuant to a warrant—'that there was no probable cause supporting the issuance of the warrant or that the search was otherwise unreasonable.'" A-0045-25 11 State v. Myers, 357 N.J. Super. 32, 40 (App. Div. 2003) (quoting State v. Sullivan, 169 N.J. 204, 211 (2001)). The role of a reviewing court "is not to determine anew whether there was probable cause for issuance of the warrant." Chippero, 201 N.J. at 20. Rather, review of the sufficiency of a warrant is confined to assessing whether adequate evidence exists within the confines of the affidavit to support the probable cause finding made by the warrant-issuing judge. Id. at 20-21, 32. A. Through this deferential lens, we first consider defendant's argument the court erroneously authorized a search of the Collings Road residence.3 Well settled constitutional principles govern our review. 3 We note defendant sporadically weaves throughout his moving brief, specifically in footnotes, challenges to Detective Palermo's reliability and credibility. See Almog v. Israel Travel Advisory Serv., Inc., 298 N.J. Super. 145, 155 (App. Div. 1997) (on appeal the respondent "need not respond to oblique hints and assertions made in footnotes" and that the court may "confine [its] address of the issues to those arguments properly made under appropriate point headings"). He echoes his claims before the motion court asserting the detective was improperly trained and omitted material information impacting the sufficiency of the affidavit. Defendant does not raise this claim in his notice of appeal or case information statement. Park Crest Cleaners, LLC v. A Plus Cleaners & Alterations Corp., 458 N.J. Super. 465, 472 (App. Div. 2019) ("A party's failure to seek review of cognizable trial court orders or determinations — by identifying them in the notice of appeal—is largely fatal."). Further, as the trial court properly noted, a challenge to the veracity or trustworthiness of the A-0045-25 12 "The Fourth Amendment to the United States Constitution and Article I, Paragraph 7 of the New Jersey Constitution protect individuals' rights 'to be secure in their persons, houses, papers, and effects' by requiring that search warrants be 'supported by oath or affirmation' and describe with particularity the places subject to search and people or things subject to seizure." State v. Andrews, 243 N.J. 447, 464 (2020). "Before issuing a warrant, the judge must be satisfied that there is probable cause to believe that a crime has been committed, or is being committed, at a specific location or that evidence of a crime is at the place sought to be searched." Sullivan, 169 N.J. at 210. "Probable cause for the issuance of a search warrant requires 'a fair probability that contraband or evidence of a crime will be found in a particular place.'" Chippero, 201 N.J. at 28 (quoting United States v. Jones, 994 F.2d 1051, 1056 (3d Cir. 1993)). Further, "[t]he probable cause determination must be . . . based on the information contained within the four corners of the supporting affidavit, as supplemented by sworn testimony before the issuing judge that is recorded affiant's representations required a motion pursuant to Franks v. Delaware, 438 U.S. 154, 155-56 (1978), which defendant conceded he never filed. Thus, we consider defendant's claims only in our overall assessment of the sufficiency of the evidence in the affidavit as to probable cause. A-0045-25 13 contemporaneously." State v. Marshall, 199 N.J. 602, 611 (2009) (quoting Schneider v. Simonini, 163 N.J. 336, 363 (2000)). Searches of the home should be reviewed carefully as "'the home is first among equals.' Accordingly, constitutional protection against unlawful searches and seizures applies with maximum force to governmental intrusions into the home." State v. Ingram, 474 N.J. Super. 522, 535 (App. Div. 2023) (quoting Florida v. Jardines, 569 U.S. 1, 6 (2013)). Here, defendant invokes Boone and contends the warrant affidavit failed to present a sufficient nexus between the criminal activity and the Collings Road location. However, careful review of the Boone Court's decision, and the affidavit it found lacking, demonstrates the Court focused its inquiry on the absence of adequate proof connecting the defendant to the residence to be searched. Indeed, the Court framed the issue before it as "whether a warrant application that did not include evidence as to why a specific apartment unit should be searched fell short of establishing probable cause for the search of that apartment." Boone, 232 N.J. at 421. Answering its question in the circumstances presented, the Court determined "there was nothing in the affidavit to indicate where Boone lived, how police knew which apartment was his, or how the apartment was connected to his drug dealing." Id. at 430. A-0045-25 14 By ready contrast, the affidavit here contained ample evidence connecting defendant to the Collings Road residence. Personal and GPS surveillance demonstrated defendant's regular presence at the residence over a sustained period of time. This was not an apartment complex with a common entryway or access point. This was a single residence, with its own door, to which defendant had been sufficiently tethered. The closer call here concerns the nexus between the Collings Road residence and the alleged drug activity. However, mindful of our deferential standard of review and affording the warrant its presumed validity, we are satisfied the motion court did not err in denying the motion to suppress the evidence seized from Collings Road because the affidavit presented sufficient facts to support a finding of probable cause to connect the residence to defendant and his alleged criminal activity. In his affidavit, Detective Palermo, experienced and trained in narcotics investigations, detailed this investigation and evidence giving rise to a well-grounded suspicion defendant's residence on Collings Road would reveal evidence of drug activity, including possession and possession of CDS with intent to distribute. Acting on the initial information, investigators readily confirmed defendant operated the Chrysler 300 identified by the informant, which was seen A-0045-25 15 regularly parked outside the Collings Road residence. Defendant had a criminal history as did the then-incarcerated owner of the Chrysler. Over the span of several months, detectives repeatedly observed defendant entering and exiting the residence from and into the Chrysler. The home was outfitted with its own camera trained on the front steps. Significantly, police observed defendant repeatedly leaving Collings Road in the Chrysler and on several occasions proceeding directly to meet with various suspected drug sellers, whom detectives independently determined engaged in hand-to-hand transactions close in time to meeting defendant and at locations where each met defendant. During one meeting, a seller reached into the Chrysler before leaving defendant and resuming the hand-to-hand exchanges. Investigators then utilized confidential informants, previously proven reliable in making prior drug arrests, to make controlled purchases of CDS from the sellers with whom defendant had met each time. Investigators surveilled defendant and on one occasion followed him as he drove away erratically from Collings Road in the Chrysler, turning and accelerating in an evasive manner indicative of his attempting to thwart surveillance or avoid detection. This information, taken as a whole, sufficiently supported a well-grounded suspicion A-0045-25 16 that evidence related to drug possession and sales would be found in defendant's residence. Defendant also challenges use of information from the various informants to support probable cause, claiming they were unreliable and, thus, their information improperly anchored the warrant. Viewing the facts asserted in the affidavit in their entirety, we are unpersuaded. Here, the affidavit contained sufficient evidence to corroborate the initial report to police regarding defendant's involvement in drug sales throughout Camden. The reliable informants who made the controlled purchases had assisted in securing drug arrests in the past and were closely observed by detectives at all stages of the relevant purchases in this investigation. Further, the additional information provided by those not expressly designated in the affidavit as reliable in the past did not form the sole, or even substantial, basis for the probable cause. "Information provided by an informant may constitute a basis for a finding of probable cause, so long as there is a substantial basis for crediting th e information." Sullivan, 169 N.J. at 212. When determining the reliability of this information, an "issuing court must consider the 'veracity and basis of knowledge' of the informant as part of its 'totality' analysis." Jones, 179 N.J. at 389 (quoting State v. Novembrino, 105 N.J. 95, 123 (1987)). Nonetheless, "if A-0045-25 17 the informant's tip fails to demonstrate sufficient veracity or basis of knowledge, a search warrant issued on the basis of the tip may still pass muster if other facts included in a supporting affidavit justify a finding of probable cause." Jones, 179 N.J. at 390. "[R]elevant corroborating facts may include a controlled drug buy performed on the basis of the tip, positive test results of the drugs obtained, records confirming the informant's description of the target location, the suspect's criminal history . . . the experience of the officer who submitted the supporting affidavit," State v. Keyes, 184 N.J. 541, 556 (2005), as well as a "corroborative investigation." Sullivan, 169 N.J. at 214. The veracity factor is met if the affiant can demonstrate "that the informant has proven reliable in the past," Keyes, 184 N.J. at 555, as the information provided led to an arrest. Id. at 557. There is no bright line rule for determining what evidence will constitute probable cause in any given case as these are fact-sensitive determinations. As to informant information, "[t]he degree of corroboration that the police must present to the issuing court depends on a qualitative analysis of the 'unique facts and circumstances presented in each case.'" Id. at 556 (quoting Jones, 179 N.J. at 390). Ultimately, we recognize, probable cause for a search warrant remains A-0045-25 18 "a flexible, nontechnical concept," Sullivan, 169 N.J. at 211 (quoting State v. Kasabucki, 52 N.J. 110, 116 (1968)), which we conclude was satisfied here. Although we again note defendant highlights information that was missing from the affidavit, such as any evidence of a drug purchase from defendant or his possession of a container or bag to transfer or supply drugs, and also attempts to cast aspersions on Detective Palermo's training, we are not persuaded these claims undermine or render less weighty the proof supporting the warrant. B. We next address defendant's claim the affidavit lacked a basis for the no- knock order. Importantly, "law enforcement officers generally are required to knock and announce their presence before entering a dwelling." Jones, 179 N.J. at 397. But this mandate is not absolute. State v. Johnson, 168 N.J. 608, 616 (2001). Particularly, "law enforcement interests may . . . establish the reasonableness of an unannounced entry." Id. at 617. In New Jersey, exceptions to the knock-and-announce rule apply when: "(1) immediate action is required to preserve evidence; (2) the officer's peril would be increased; or (3) the arrest would be frustrated." Ibid. (quoting State v. Fair, 45 N.J. 77, 86 (1965)). To obtain a no-knock warrant, the applying officer must "articulate[] a reasonable suspicion to believe that one or more exceptions to the knock and A-0045-25 19 announce rule are justified." Id. at 618. The evidence the officer provides may be based on the totality of the circumstances. Ibid. (quoting State v. Davis, 104 N.J. 490, 504 (1986)). Reasonable suspicion is a lower bar to meet than probable cause, but it "requires at least a minimal level of objective justification for [taking the police action]," ibid. (alteration in original) (quoting Illinois v. Wardlow, 528 U.S. 119, 123 (2000)), not simply a hunch. Wardlow, 528 U.S. at 123. Although "a suspect's criminal history may be used as part of the totality of the circumstances analysis to justify a no-knock entry, . . . the nature of the prior criminal behavior and the passage of time are especially important factors that will often dictate what additional showing to the court may be required." Jones, 179 N.J. at 399-400. When determining the relevance of a suspect's criminal history to the question of reasonable suspicion supporting no-knock entry, we balance the nature of the prior offense with its remoteness. See ibid. Other factors such as the presence of surveillance equipment monitoring the property may heighten concerns warranting an exception. We have held: the presence of a surveillance camera and other monitoring equipment to view potential narcotics customers and law enforcement personnel as they approach a drug distribution location can form the basis for an officer's particularized suspicion that a "no- A-0045-25 20 knock" search warrant is necessary to prevent the destruction of evidence and [e]nsure officer safety. [State v. Carlino, 373 N.J. Super. 377, 392 (App. Div. 2004).] Here, we are satisfied the warrant affidavit sufficiently supported the no- knock order. The totality of information included defendant's temporally remote but not insignificant conviction for the violent crime of aggravated manslaughter and a more-recent conviction for firearm possession, an informant's claim defendant had been in possession of a gun, and the existence of a surveillance camera trained on the front steps. Although defendant correctly notes the affidavit provides no information concerning the informant who provided the tip about defendant's firearm, we do not view that small detail as tilting the scale. Taking the affidavit in the aggregate, and even excluding the informant's report for purposes of argument, we remain persuaded sufficient facts existed to support the no-knock order to protect the officers' safety and preserve evidence. Affirmed. A-0045-25 21