NJ appeals court upholds no-knock police raid

Judges rule that police had sufficient grounds to enter a Camden home without announcing themselves.

A New Jersey appeals court has upheld a Camden man’s drug and weapons convictions, ruling that police were justified in entering his home without knocking because of his criminal history, outdoor surveillance cameras, and reports that he carried a gun.

The Oct. 23 ruling offers a look at how courts apply New Jersey’s restrictions on no-knock warrants, a controversial police tactic.

In an unpublished opinion, Appellate Division Judges Maritza Berdote Byrne and Ellen Torregrossa-O’Connor rejected a challenge by Rahmeen Pratt, 45, who argued that police lacked sufficient evidence to search his Camden home and should not have been granted permission to enter without knocking.

The decision leaves intact Pratt’s convictions for drug distribution and unlawful firearm possession, for which he is serving a nine-year prison sentence.

Under ordinary circumstances, police executing a search warrant must knock, identify themselves, and give occupants a reasonable opportunity to respond before entering.

Exceptions allow officers to enter without warning when they can demonstrate that announcing themselves would endanger officers or others, allow evidence to be destroyed, or prevent an arrest.

New Jersey adopted stricter rules in 2021 prohibiting no-knock warrants except when officers can demonstrate specific safety concerns. The statewide directive requires approval from a county prosecutor or other designated senior official before police seek such a warrant.

No-knock searches must be conducted by specially trained tactical teams, and the operations are subject to subsequent review. The restrictions were intended to address the dangers associated with officers entering homes without warning, including the risk of violent confrontations and harm to residents.

Pratt’s appeal stemmed from a Camden County Police Department investigation into suspected drug distribution in Camden.

According to court documents, investigators used physical surveillance, GPS tracking, and confidential informants to link Pratt to several street-level drug dealers.

Police observed Pratt repeatedly leaving his Collings Road home before meeting with suspected dealers. Confidential informants subsequently purchased crack cocaine and heroin from those dealers, investigators said.

Detective Nicholas Palermo argued in a search warrant affidavit that the surveillance established probable cause to believe police would find evidence of drug trafficking inside Pratt’s home.

Pratt’s attorney, Jordan Zeitz, argued that investigators had not established a sufficient connection between the suspected drug activity and the house. He also questioned the reliability of the confidential informants.

The appeals court judges disagreed, finding that investigators had corroborated the informants’ information through surveillance and controlled drug purchases.

“This information, taken as a whole, sufficiently supported a well-grounded suspicion that evidence related to drug possession and sales would be found in defendant’s residence,” the judges wrote.

The judges also considered whether investigators had sufficient grounds to seek permission to enter Pratt’s home without warning.

Police cited his prior convictions, including aggravated manslaughter in 1998 and unlawful handgun possession in 2021. Investigators also reported that Pratt had surveillance cameras outside his home and that an informant had indicated he carried a handgun.

The judges concluded that those circumstances, considered together, justified the no-knock provision.

“We remain persuaded sufficient facts existed to support the no-knock order to protect the officers’ safety and preserve evidence,” they wrote.

When officers searched the house on May 10, 2024, they recovered guns, ammunition, approximately 20 ounces and 150 capsules of cocaine, more than 100 oxycodone pills, $2,000 in cash, and drug paraphernalia, according to court documents.

After a lower court refused to suppress the evidence, Pratt pleaded guilty to second-degree possession of drugs with intent to distribute and second-degree unlawful firearm possession by a person prohibited from possessing firearms.