State v. Pulizzi

Ruled that the criminal defendant did not have an objectively reasonable expectation of privacy in his curbside garbage based on the city’s waste collection ordinance requiring special permission from the city for an exemption from waste collection service, and thus police officers’ warrantless trash pulls from defendant’s garbage did not violate search and seizure provision of State Constitution. The ordinance did not require residents to dispose of their personal effects into garbage receptacles that were accessible to public and law enforcement, residents had other lawful means to discard their trash, such as burning garbage after obtaining a permit or personally transporting garbage to the county transfer station, and the ordinance did not prohibit residents from creating an alternative garbage collection and disposal arrangement with a contractor that protected their private information.