New Jersey Libertarian Party

The Party of Principle

Internal Affairs Complaint - Neptune Township

July 26, 2017

Internal Affairs Unit
Neptune Township Police Department
25 Neptune Blvd.
Neptune, NJ 07753
(via fax only to 732-774-0982 )

RE: Officer Aaron Lay

Dear Sir or Madam:

I chair the New Jersey Libertarian Party's Police Accountability Project and ask that you accept this letter as an Internal Affairs complaint. Note that this is the second complaint we have filed regarding a warrantless strip search. Our first complaint was filed on March 18, 2013 and reported that Lieutenant Robert Mangold had conducted a warrantless strip search that resulted in two glassine bags of heroin being suppressed by the court. Notwithstanding the court's finding, your Internal Affairs Unit exonerated Mangold after finding that he "followed the appropriate department policies and procedures."

Our current complaint is based on the Appellate Division's July 26, 2017 reversal of a conviction in State v. Asim Q. Jules. The court found that Officer Lay, with his shift commander's permission, conducted a warrantless strip search on September 29, 2014 and found a"translucent orange prescription pill bottle clenched between [Defendant's] legs." The bottle contained eight alprazolam tablets.

The Appellate Division panel found that the strip search was not justified absent a warrant or the defendant's consent. Since your department had neither a warrant nor consent, the court concluded that "the police did not act reasonably in this matter" and ordered that the judgment of conviction be reversed.

It seems to us that Lay, the shift commander and other officers, given the reversal that arose our of Mangold's improper strip search, should have known better than to engage in this warrantless strip search. Accordingly, we ask that you investigate Lay, the shift commander and other officers and take appropriate disciplinary action against them.

Thank you for your attention to this matter.

Very truly yours,

John Paff, Chairman
New Jersey Libertarian Party
Police Accountability Project
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

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