State v. Duran C. Keaton, 222 N.J. 438 (2015)

A handgun and bag of marijuana found in defendant's overturned car did not fall within the plain view exception to the warrant requirement, and were illegally seized. The law enforcement officer was required to provide defendant with the opportunity to present his credentials before entering the vehicle. If after giving a defendant that opportunity, he or she is unable or unwilling to produce the registration or insurance information, only then may an officer conduct a search for those credentials. Here, because defendant was never provided with such an opportunity, the seizure of the contraband was unlawful under the plain view doctrine. Further, the community-caretaking doctrine was inapplicable because there was no need for an immediate warrantless search to preserve life or property.