The inevitable discovery doctrine may be invoked to "preserve - if certain conditions are satisfied - the admissibility of evidence obtained without a warrant or a valid exception to the warrant requirement." State v. Camey, 239 N.J. 282, 301 (2019).

Schneckloth v. Bustamonte, 412 U.S. 218, 219 (1973); State v. Camey, 239 N.J. 282, 300 (2019).

That doctrine "allows for the introduction of evidence tainted by unlawful police conduct if the information leading to discovery of the evidence is independent of the previous unlawful conduct." State v. Camey, 239 N.J. 282, 310 (2019) (citing Nix v. Williams, 467 U.S. 431, 443 (1984)). Consequently, the independent source doctrine allows for the "admission of evidence that was discovered wholly independently from the constitutional violation." State v. Shaw, 237 N.J. 588, 621 (2019).

Its purpose is to "prevent[ ] the prosecution from being in a better position than if the illegal conduct had not taken place" rather than to "punish the prosecution by putting it in a worse place." State v. Camey, 239 N.J. 282, 302, 217 A.3d 106 (2019) (citing Sugar II, 100 N.J. at 237, 495 A.2d 90 ). The State must demonstrate that:

Its purpose is to "prevent[] the prosecution from being in a better position than if the illegal conduct had not taken place" rather than to "punish the prosecution by putting it in a worse place." State v. Camey, 239 N.J. 282, 302 (2019) (citing Sugar II, 100 N.J. at 237). The State must demonstrate that

The independent source doctrine "allows for the introduction of evidence tainted by unlawful police conduct if the information leading to discovery of the evidence is independent of the previous unlawful conduct." State v. Camey, 239 N.J. 282, 310 (2019) (citing Nix v. Williams, 467 U.S. 431, 443 (1984)). Consequently, the independent source doctrine allows for the "admission of evidence that was discovered wholly independently from the constitutional violation."

Indeed "the Prosecutor's Office recommended [its] dissolution." Further, contrary to Bordamonte's belief that he is the "Michael Jordan" of police officers, App. at 255, he had a troubled relationship with the community he served, having been caught on video telling minority residents that he is "gonna have immigration pick everybody up so they can cross back to the fucking border in Puebla or wherever the fuck [they] came from," App. at 287; cf. State v. Camey, 217 A.3d 106, 119-20 (N.J. 2019) (the New Jersey Supreme Court criticizing Bordamonte's failure to obtain a search warrant in a 2013 investigation). And finally, although Bordamonte complained that Danna interfered with his use of vacation days, it is not apparent what adversity that caused at all because he was able to use all his vacation days while under Danna's command.

" City of Passaic Mot., Ex. J. The Prosecutor's Office expressed concern regarding the QOL Unit's tactics. City of Passaic Mot., Ex. L, 49. Finally, Defendants point to the December 10, 2019 New Jersey Superior Court decision in State v. Rafael Camey, Ind. No. 14-11-00923—which followed the New Jersey Supreme Court's similar decision in State v. Camey, 217 A.3d 106, 109 (2019) condemning Plaintiff's tactics and affirming suppression of buccal swab DNA evidence obtained by Plaintiff or those under his command—concluding that Plaintiff illegally targeted individual who were homeless and Hispanic and violated their constitutional rights in order to secure convictions. Ex. M. The Court concludes that in light of this overwhelming evidence, the QOL Unit would have been disbanded in the absence of Plaintiff's political advocacy and affiliation.

Before conducting a search, the police must obtain a warrant from a neutral judicial officer "unless the search falls within a recognized exception to the warrant requirement." State v. Camey, 239 N.J. 282, 298, 217 A.3d 106 (2019). "When no warrant is sought, the State has the burden to demonstrate that ‘[the search] falls within one of the few well-delineated exceptions to the warrant requirement.’ "

Specifically, the police "took no affirmative steps to secure legal process" independent of the illegal search. Statev. Camey, 239 N.J. 282, 306 (2019); see also Premone, 348 N.J.Super. at 510 (refusing to apply the inevitable discovery doctrine where the State argued it could have obtained information by way of a search warrant but had not taken any steps to do so). It is not enough for the State to argue "had that search warrant been submitted to the [c]ourt[,] . . . the [c]ourt would have granted that search warrant."