Accreditation
CALEA
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NJSACOP NJLEAP
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Federal Courts
United States Supreme Court
No Updates.
U.S. Third Circuit Court of Appeals
United States v. Davone Walker, No. 25-2118
Decision Date: September 1, 2026
Executive Summary
The U.S. Court of Appeals for the Third Circuit considered whether evidence should be suppressed after law-enforcement officers entered a residence during a controlled-delivery operation without authorization in the existing warrant or tracking order.
Investigators had arranged a controlled delivery of a package containing methamphetamine and were monitoring the package through a tracking device. After the package was taken into an apartment, officers entered and secured the residence while seeking additional judicial authorization. The Third Circuit assumed for purposes of its analysis that the warrantless entry violated the Fourth Amendment.
The Court nevertheless concluded that suppression of the subsequently obtained evidence was not warranted. The exclusionary rule is intended primarily to deter deliberate, reckless, grossly negligent, or recurring law-enforcement misconduct. The officer's conduct in this case was characterized as an isolated mistake rather than sufficiently culpable conduct requiring suppression.
Administrative and Operational Impact
The decision is directly relevant to search-warrant execution, controlled deliveries, residential entry, and the limits of the exclusionary rule.
The opinion does not authorize officers to enter a residence merely because contraband or a tracked package has entered the location. Officers must continue to operate within the scope of judicial authorization unless a recognized exception to the warrant requirement applies.
The decision is significant because it distinguishes the existence of a possible Fourth Amendment violation from the separate question of whether suppression is an appropriate remedy. Evidence is not automatically suppressed whenever an officer makes a constitutional mistake. Courts must also evaluate the officer's level of culpability and whether suppression would meaningfully deter future police misconduct.
For agencies, the operational lesson remains that controlled-delivery plans should clearly address contingencies involving movement of evidence into locations not covered by the original warrant or tracking authorization.
Action Required
No immediate policy revision is required solely because of this decision.
Agencies should ensure that search-warrant and controlled-delivery training emphasizes:
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the precise scope of judicial authorization;
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the requirement for additional judicial authorization before entering a newly implicated residence unless a warrant exception applies;
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documentation of exigent circumstances when relied upon;
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supervisory coordination during controlled-delivery operations; and
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the distinction between a constitutional violation and application of the exclusionary rule.
The decision is appropriate for inclusion in legal-update training for detectives, narcotics personnel, supervisors, and officers involved in warrant execution.
Source Document
View U.S. Third Circuit Court of Appeals Decision
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United States v. Diego Edgardo Aleman-Lozano, No. 25-3012
Decision Date: September 1, 2026
Executive Summary
The U.S. Court of Appeals for the Third Circuit upheld the constitutionality of 18 U.S.C. § 922(g)(5)(B), which prohibits certain persons admitted to the United States under nonimmigrant visas from possessing firearms.
The case originated with a Pennsylvania State Police traffic stop. During the encounter, a trooper observed a rifle cartridge, which contributed to further investigation and the subsequent issuance of a search warrant. Officers recovered a loaded unserialized handgun from Aleman-Lozano's residence.
Aleman-Lozano challenged his federal conviction on Second Amendment grounds. The Third Circuit rejected the facial challenge and concluded that the federal prohibition is constitutionally permissible. The precedential decision therefore leaves § 922(g)(5)(B) enforceable within the Third Circuit.
Administrative and Operational Impact
The decision is relevant primarily to firearms investigations and cases involving individuals whose immigration status may affect their legal eligibility to possess firearms.
For state and local law-enforcement officers, the decision does not create a new investigative authority or independent basis for detention, search, or arrest. Officers must continue to establish the appropriate constitutional and statutory basis for any investigative action.
The decision does, however, confirm that § 922(g)(5)(B) remains a viable federal firearms offense within the Third Circuit despite contemporary Second Amendment challenges. This may be significant when state or local investigations identify potentially prohibited firearm possession and referral to federal authorities is appropriate.
Action Required
No immediate agency policy amendment is required.
Firearms investigators, detectives, intelligence personnel, and officers assigned to federal task forces should be aware that the Third Circuit has upheld § 922(g)(5)(B) against a facial Second Amendment challenge.
Agencies should continue to coordinate with appropriate federal authorities when an investigation develops evidence that an individual may be prohibited from possessing firearms under federal law. Immigration status alone should not be treated as a substitute for the legal predicates required for a stop, search, detention, or arrest.
Source Document
View U.S. Third Circuit Court of Appeals Decision
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United States v. Joseph Paul Berger, No. 24-2125
Decision Date: September 1, 2026
Executive Summary
The U.S. Court of Appeals for the Third Circuit rejected Second Amendment challenges involving the possession of machine guns and federal registration requirements applicable to firearm silencers.
Berger was convicted of possessing machine guns and unregistered silencers. He argued that the Second Amendment protected his possession of the machine guns and that the National Firearms Act's registration requirements for silencers were unconstitutional.
The Third Circuit rejected both arguments. The Court held that machine guns are not protected by the Second Amendment because they are not weapons commonly possessed for lawful purposes. The Court also upheld the federal silencer-registration requirement, concluding that the registration requirement does not impermissibly burden Second Amendment rights.
Administrative and Operational Impact
The decision provides precedential Third Circuit guidance concerning two categories of weapons that frequently arise in federal firearms investigations: machine guns and silencers.
For state and local law-enforcement agencies, the decision does not change ordinary firearms seizure, arrest, or search procedures. It does reinforce the continuing constitutional validity of federal machine-gun restrictions and federal registration requirements applicable to silencers.
The decision may be particularly useful to firearms investigators, bomb squad or tactical personnel, evidence personnel, and officers participating in ATF or other federal task-force investigations where prohibited automatic weapons or silencers are encountered.
Action Required
No immediate policy revision is required.
Agencies should ensure that personnel involved in firearms investigations understand that:
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the Third Circuit does not recognize a Second Amendment right to possess machine guns;
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federal silencer-registration requirements remain constitutionally enforceable;
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suspected machine guns and silencers should be properly identified, secured, documented, and referred for appropriate criminal investigation; and
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federal firearms cases should be coordinated with ATF or the appropriate federal prosecuting authority when applicable.
The decision may be incorporated into firearms-law and legal-update training.
Source Document
View U.S. Third Circuit Court of Appeals Decision
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United States v. LaMonica McIver, Nos. 25-3573 & 26-1122
Decision Date: August 26, 2026
Executive Summary
The U.S. Court of Appeals for the Third Circuit considered whether Congresswoman LaMonica McIver could obtain dismissal of federal criminal charges arising from her conduct during a congressional oversight visit to the Delaney Hall federal immigration detention facility in Newark, New Jersey. McIver argued that the Speech or Debate Clause, separation-of-powers principles, and constitutional protections against selective and vindictive prosecution barred the prosecution.
The Third Circuit largely rejected those arguments and permitted the prosecution to proceed. The court concluded that legislative immunity does not categorically shield a Member of Congress from prosecution for alleged physical conduct involving federal law-enforcement officers merely because the incident occurred during an otherwise legitimate oversight visit.
Administrative and Operational Impact
The decision has limited direct operational impact on New Jersey state, county, or municipal law-enforcement agencies because the case concerns federal officers, congressional immunity, and the scope of federal criminal prosecution.
Its broader law-enforcement significance is that the court distinguished protected legislative activity from alleged physical conduct directed toward law-enforcement personnel. The decision reinforces that a person's official governmental status does not necessarily immunize conduct that independently may constitute interference with or assault upon law-enforcement officers.
The opinion does not establish new arrest, use-of-force, detention, investigation, or reporting procedures for New Jersey law-enforcement agencies.
Action Required
No immediate policy or operational action is required.
Agencies should retain the decision for legal-awareness purposes, particularly personnel involved in executive protection, demonstrations, federal task-force operations, immigration-related events, or incidents involving elected officials. No amendment to existing agency policy is presently indicated solely because of this decision.
Source Document
View U.S. Third Circuit Court of Appeals Decision
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New Jersey State Courts and Legislature
New Jersey Supreme Court
State v. Jamar J. Myers
Decision Date: August 17, 2026
Executive Summary
The New Jersey Supreme Court held that Jamar Myers must be permitted to withdraw his guilty plea to felony murder after successfully challenging evidence that had been central to a global plea agreement covering two separate criminal indictments.
Myers had pleaded guilty to felony murder in one case and armed robbery in another while expressly preserving his right to appeal the denial of a suppression motion. The Supreme Court had previously ruled that police lacked reasonable and articulable suspicion to stop the vehicle in which Myers was riding, resulting in suppression of clothing and money seized following the stop and vacation of his armed-robbery conviction. Because that same evidence had also been approved for use against Myers in the felony-murder prosecution, its suppression materially changed the evidentiary posture underlying the global plea agreement. The Court therefore held that, under Rules 3:5-7 and 3:9-3(f), Myers must be allowed to withdraw the felony-murder plea as well.
The Court emphasized that its holding is limited to the particular circumstances of this case and does not establish that every successful appeal involving one count or indictment automatically permits withdrawal from an entire global plea agreement.
Administrative and Operational Impact
The decision has limited direct impact on routine police operations, but it reinforces the substantial downstream consequences that can result from an unconstitutional investigative detention or vehicle stop.
Evidence obtained from the unlawful stop did not affect only the prosecution arising directly from that stop. Because prosecutors intended to use the same evidence under N.J.R.E. 404(b) in a separate homicide prosecution, suppression ultimately affected the viability and terms of a broader plea agreement involving multiple cases.
For law-enforcement agencies, the decision reinforces the importance of ensuring that investigative stops are supported by specific, articulable facts establishing reasonable suspicion. Evidence obtained through an unconstitutional stop may affect not only the immediate investigation but also related prosecutions in which that evidence is later used to establish identity, motive, intent, or another permissible evidentiary purpose.
Action Required
No new policy amendment is required solely because of this decision.
Agencies should ensure that existing training and written directives concerning investigative detentions and motor-vehicle stops continue to emphasize the requirement for individualized reasonable and articulable suspicion.
Supervisors, trainers, and legal instructors may also use the case to demonstrate how an unlawful stop can have consequences extending beyond suppression in the originating case, including the loss of evidence in related prosecutions and disruption of negotiated plea agreements.
Source Document
View N.J. Supreme Court Decision
Listen to Oral Arguments Audio
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New Jersey Appellate Division
No Updates.
New Jersey Legislature
No Updates.
Other Primary Sources
FBI CJIS Security Policy
Current Version: Version 6.1
Last Updated: 06/25/2026
Previous Version: Version 6.0 published on 12/27/2024
Executive Summary of Changes
The FBI published CJIS Security Policy Version 6.1 on June 25, 2026, replacing Version 6.0. Version 6.0 represented completion of the FBI's modernization of the CJIS Security Policy. Version 6.1 incorporates calendar year 2025 changes and addresses omissions, corrections, and additions identified following implementation of the modernized policy.
The Version 6.1 changes were approved through three Spring 2025 Advisory Policy Board actions: APB #16, SA #1; APB #16, SA #2; and APB #16, SA #3, collectively addressing omissions, corrections, and additions to the modernized CJIS Security Policy. Version 6.1 also incorporates administrative changes approved by the Security and Access Subcommittee on November 14, 2025.
Unlike Version 6.0, which completed substantial modernization of the policy structure and security-control framework, Version 6.1 primarily refines and corrects that modernized framework while incorporating newly approved requirements. The accompanying FBI Requirements Companion Document provides a control-by-control comparison between Versions 6.0 and 6.1 and identifies the applicable audit/sanction status, control priority, and cloud-service responsibility for each requirement.
Administrative and Operational Impact
Agencies should not treat Version 6.1 as an administrative republication of Version 6.0. The FBI states that the policy contains requirements carried forward from previous versions along with newly approved requirements for agencies to implement. Agencies should therefore evaluate Version 6.1 against their existing CJIS compliance program rather than assuming compliance with Version 6.0 automatically establishes compliance with Version 6.1.
The Version 6.1 Requirements Companion Document is particularly important for implementation because it identifies:
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the corresponding Version 6.0 and Version 6.1 control locations;
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the specific required “shall” statements;
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each control's audit/sanction status;
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the assigned Priority level; and
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responsibility for implementation in IaaS, PaaS, and SaaS cloud environments.
The FBI distinguishes existing requirements from modernized requirements that remain within the implementation cycle. Controls carried forward from Version 5.9 are identified as Existing. Certain subsequently modernized controls are identified as Zero-cycle, which began October 1, 2024. Priority 1 (P1) controls are immediately sanctionable upon publication of the CJIS Security Policy version in which they first appear.
For agencies using cloud services, the Companion Document also identifies whether implementation responsibility rests technically with the agency, the cloud service provider, both parties, or CJIS/CSO. The FBI expressly notes that the agency remains ultimately accountable for CJIS Security Policy compliance, regardless of the allocation of technical responsibilities to a cloud provider.
Action Required
Agencies should conduct a documented Version 6.0-to-6.1 compliance review.
At a minimum, agencies should:
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Compare existing policies, procedures, technical controls, contracts, and security documentation against the Version 6.1 requirements and the FBI Requirements Companion Document.
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Identify requirements that were added, corrected, or substantively modified from Version 6.0.
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Determine the priority and audit/sanction status of each applicable requirement.
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Address Priority 1 requirements immediately where applicable because P1 controls are sanctionable upon publication of the version in which they first appear.
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Develop or update implementation plans for applicable Zero-cycle controls.
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Review cloud-service arrangements to confirm that agency and provider responsibilities are documented and that contractual allocation of responsibility does not leave a CJIS requirement unaddressed.
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Update agency CJIS-related policies, procedures, security plans, training, technical configurations, and vendor documentation where the Version 6.1 review identifies a gap.
Compliance significance: Version 6.1 is the current controlling FBI CJIS Security Policy. Agencies should use Version 6.1, rather than Version 6.0, as the baseline for current CJIS compliance assessments.
Source Document Links
FBI CJIS Security Policy (Download) (Version 6.1 - 06/25/2026)
FBI CJIS Security Policy Resource Center
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