New Jersey v. Prall

The Appellate Division reversed defendant Tormu Prall’s conviction, finding that: (1) his prior threat to kill his girlfriend, Jessie Harley, was admitted in error and without a limiting instruction; (2) the State improperly utilized prior bad act evidence in closing; and (3) statements by defendant’s brother John Prall to John’s girlfriend Kimberly Meadows were inadmissible hearsay and did not qualify as dying declarations or excited utterances. Defendant was convicted for the arson murder of his brother. The New Jersey Supreme Court granted the State’s petition for certification and reversed the Appellate Division and reinstated defendant’s convictions. The Supreme Court agreed with the appellate panel’s legal conclusions that the trial court erred by allowing evidence that defendant threatened to burn down Jessie’s homes and by admitting John’s hearsay statements to Kimberly that defendant was responsible for the arson. However, the Court found the errors were not capable of producing an unjust result because of the overwhelming weight and quality of the evidence against defendant. View "New Jersey v. Prall" on Justia Law