Justia New Jersey Supreme Court Opinion Summaries

Police responded to a report of gunshots and encountered the defendant walking with two others. When approached by officers, the defendant fled and was seen discarding a loaded handgun. He was apprehended and charged with several offenses, including unlawful possession of a weapon and possession of a weapon for an unlawful purpose, both of which are subject to mandatory minimum sentences under New Jersey’s Graves Act. The defendant, who had no adult criminal convictions, requested a waiver of the mandatory minimum sentence, but the prosecutor denied the request, citing the seriousness of the conduct and the risks posed during the incident.The defendant pled guilty to unlawful possession of a weapon, and the trial court found the aggravating and mitigating factors to be balanced. During sentencing, the court learned of the prior denial of the Graves Act waiver and postponed sentencing for further explanation. The defendant then moved to override the prosecutor’s denial. The Superior Court of New Jersey, Law Division, determined that the defendant had not shown the prosecutor’s decision was a patent and gross abuse of discretion and sentenced him according to the plea agreement. On appeal, the defendant argued that the trial court should have applied the less deferential abuse of discretion standard. The Superior Court of New Jersey, Appellate Division, affirmed, holding that the patent and gross abuse of discretion standard applied.The Supreme Court of New Jersey reviewed the case to determine the correct standard for reviewing a prosecutor’s denial of a Graves Act waiver. The Court held that the appropriate standard is ordinary abuse of discretion, not the heightened patent and gross abuse of discretion standard. The Court reversed the Appellate Division’s judgment and remanded the case to the trial court to reconsider the prosecutor’s denial under the ordinary abuse of discretion standard. View "State v. Taylor" on Justia Law

Police arrested the defendant in August 2021 on an outstanding robbery warrant and found a handgun believed to be his. He was charged with several offenses, including first-degree unlawful possession of a weapon under N.J.S.A. 2C:39-5(b)(1) and (j), the latter applying when a person with a prior conviction subject to the No Early Release Act (NERA) commits an unlawful weapons possession offense. The defendant had a 2017 reckless manslaughter conviction, qualifying as a NERA offense. Pursuant to a plea agreement, he pled guilty to the first-degree weapons charge, and the State recommended a ten-year sentence with a five-year mandatory parole disqualifier under the Graves Act. Defense counsel reserved the right to argue that the Graves Act did not apply to subsection (j).The Superior Court, Law Division, imposed the recommended sentence, including the Graves Act parole disqualifier. On appeal, the Superior Court, Appellate Division, affirmed, reasoning that subsection (j) was a grading statute that elevated the degree of the underlying offense and thus permitted application of the Graves Act’s mandatory minimums. The Appellate Division relied on legislative history and policy arguments, concluding that excluding subsection (j) from the Graves Act would produce an “absurd” result.The Supreme Court of New Jersey reviewed the case and reversed. The Court held that N.J.S.A. 2C:39-5(j) creates a distinct, substantive first-degree offense that must be charged and proven independently, not merely a sentencing enhancement or grading provision. Because the Graves Act does not expressly include subsection (j) among the offenses subject to its mandatory parole ineligibility, a conviction under subsection (j) does not trigger the Graves Act’s mandatory minimums. The case was remanded for resentencing without the Graves Act parole disqualifier. View "State v. Cromedy" on Justia Law

In August 2019, a Jersey City Police Department (JCPD) lieutenant fired a shotgun during an argument with his girlfriend, leading to his arrest and charges of terroristic threats and possession of a weapon for an unlawful purpose. He pled guilty to a lesser charge and completed a pre-trial intervention program. The JCPD conducted an internal affairs (IA) investigation, resulting in a ninety-day suspension for the lieutenant. Plaintiff States Newsroom Inc. sought access to the IA report under the common law.The trial court denied the plaintiff's request, citing the expungement statute and an expungement order that barred the release of information related to the lieutenant’s arrest and criminal case. The court also ordered the entire docket to remain sealed. The Appellate Division reversed and remanded, instructing the trial court to apply the common law balancing test from Rivera v. Union County Prosecutors’ Office and to analyze the sealing of court documents individually.The Supreme Court of New Jersey held that the expungement statute does not categorically bar the release of IA reports but does prohibit the release of any information related to the lieutenant’s arrest, conviction, or criminal case disposition. The Court affirmed the Appellate Division’s judgment with modifications, remanding the case to the trial court to redact such information from the IA report and then conduct the common law balancing test on the remainder. If the court finds that the interests favoring disclosure outweigh confidentiality concerns, it must further redact information as specified in Rivera before releasing the report. The Court also upheld the Appellate Division’s direction regarding the sealing of court documents. View "States Newsroom Inc. v. City of Jersey City" on Justia Law

Defendant Shawn M. Fenimore arrived at the Woodstown State Police barracks on June 2, 2021, in response to a request for a statement regarding a harassment claim. New Jersey State Police Trooper Daniel Radetich interviewed Fenimore, observed signs of intoxication, and administered three sobriety tests, two of which Fenimore failed. Radetich arrested Fenimore for driving while intoxicated (DWI) and secured him to a holding cell bench. Radetich and other troopers then conducted a warrantless search of Fenimore's car, parked in the barracks parking lot, and found drugs, a loaded gun, and other evidence. Fenimore was charged with possession offenses and moved to suppress the evidence discovered during the search.The trial court denied Fenimore's motion to suppress, reasoning that police had the right to search the vehicle without a warrant based on probable cause. Fenimore pled guilty and appealed. The Appellate Division affirmed the trial court's decision, concluding that the warrantless search was justified under the automobile exception to the warrant requirement, even though the car was in a police station parking lot and subject to mandatory impoundment.The Supreme Court of New Jersey reviewed the case and held that the automobile exception to the warrant requirement did not apply under the circumstances. The Court emphasized that the car was parked in a State Police barracks parking lot, police had arrested the driver, removed the passenger, and obtained the keys, and the car was subject to imminent, mandatory impoundment. The Court concluded that there was no inherent exigency justifying a warrantless search and that the police were required to obtain a warrant before searching the vehicle. The judgment of the Appellate Division was reversed, and the case was remanded to the trial court for further proceedings consistent with the opinion. View "State v. Fenimore" on Justia Law

The State charged Ebenezer Byrd, Jerry J. Spraulding, and Gregory A. Jean-Baptiste in connection with a 2009 murder. During their trial in January 2019, allegations arose that Juror No. 8 had conducted outside research, discussed the case with third parties, texted one of the defendants, and expressed an intent to find the defendants guilty. The trial judge questioned Juror No. 8 at sidebar, asking general questions about her impartiality and whether she had been exposed to outside information. Juror No. 8 denied any misconduct. Defense counsel objected to the limited scope of the questioning and requested further inquiry, which the judge denied. The jury convicted the defendants on all counts.On appeal, Byrd’s counsel moved for a limited remand to reconstruct the record regarding Juror No. 8’s alleged misconduct. The Appellate Division ordered a remand hearing, during which the trial judge described the inquiry into Juror No. 8. The Appellate Division affirmed the convictions, holding that the trial judge’s response to the allegations did not constitute an abuse of discretion. The court found that the judge had adequately assessed the juror’s impartiality and that the allegations lacked credibility.The Supreme Court of New Jersey reviewed the case and held that the trial judge’s inquiry into the allegations was inadequate. The Court emphasized that when allegations of juror misconduct arise, the court must conduct a specific and probing examination of the juror. The trial judge failed to ask questions that directly addressed the allegations and did not conduct the inquiry outside the presence of the remaining jurors. The Court reversed the Appellate Division’s judgment and remanded the case for an evidentiary hearing, including individual voir dire of the juror, to determine whether juror taint occurred and whether further steps, including a new trial, are necessary. View "State v. Byrd" on Justia Law

In 2019, the defendant pled guilty to multiple counts of burglary and robbery. During the plea colloquy, he falsely claimed to be a U.S. citizen and stated he was born in New York, despite being born in Mexico. The presentence report noted his birthplace as Mexico but left many fields blank. At sentencing, the defendant's counsel, Carol Wentworth, reviewed the report with him, and he confirmed his U.S. citizenship. The court sentenced him to five years of Recovery Court Probation. After violating probation terms, the defendant was sentenced to five years' incarceration.The defendant later filed a petition for post-conviction relief (PCR), claiming ineffective assistance of counsel for not being informed of the immigration consequences of his plea. The PCR court found sentencing counsel ineffective for not investigating discrepancies in the presentence report and granted the petition. The Appellate Division affirmed in part, agreeing that counsel failed to advise the defendant of deportation risks but remanded for further consideration on whether the defendant could withdraw his plea.The Supreme Court of New Jersey reviewed the case and held that sentencing counsel was not constitutionally ineffective. The court found that the counsel's performance was not deficient as the presentence report did not clearly indicate non-citizenship, and the defendant repeatedly asserted his U.S. citizenship. The court emphasized that no court has required independent verification of a client's citizenship status beyond asking the client. The court reversed the Appellate Division's judgment and remanded to the PCR court for entry of an order denying the defendant's petition. View "State v. Hernandez-Peralta" on Justia Law

The case involves the Attorney General's request to empanel a special grand jury to investigate allegations of sexual abuse by clergy within the Catholic Church in New Jersey. The Diocese of Camden challenged the grand jury's authority to issue a presentment on this subject, arguing that such a presentment would not relate to public affairs or conditions as required by law.The trial court denied the Attorney General's request to empanel a special grand jury and found that the anticipated presentment was not authorized by law. The court cited the substantial commitment of time and resources needed to select unbiased grand jurors, the financial hardship on jurors, and the fact that priests are not public officials and the Catholic Church is not a public entity. The court also noted that the presentment would be fundamentally unfair to those accused, as they would not have the same protections as defendants charged by indictment. The Appellate Division summarily affirmed the trial court's judgment.The Supreme Court of New Jersey reviewed the case and reversed the lower courts' decisions. The Court held that it was premature for the trial court to conclude that any potential presentment had to be suppressed, as no grand jury had completed an investigation or issued a presentment. The Court emphasized that the relevant case law and court rule on presentments contemplate the existence of both a grand jury investigation and an actual presentment for an assignment judge to review. The Court found that the State has the right to proceed with its investigation and present evidence before a special grand jury. If the grand jury issues a presentment, the assignment judge should review the report and publish it if it complies with the legal standards outlined by the Court. The Court vacated the trial court's analysis and remanded the matter for further proceedings consistent with its opinion. View "In re the Matter Concerning the State Grand Jury" on Justia Law

John Bragg was involved in a violent altercation with Lorenza Fletcher and Daquan Anderson in an apartment in Trenton, New Jersey. Bragg claimed he had an informal sublease and had been living in the apartment for a few weeks. During the fight, all three adults sustained serious injuries, and Bragg was arrested. He was later indicted on nineteen counts, including attempted murder and kidnapping. At trial, Bragg claimed self-defense, stating that Fletcher and Anderson initiated the fight, while they testified that Bragg was the aggressor.The trial court did not instruct the jury on the "castle doctrine," which states that a person does not have to retreat from their dwelling unless they were the initial aggressor. The jury found Bragg guilty of twelve counts, including attempted murder and kidnapping. The Appellate Division affirmed the convictions, concluding that the failure to instruct on the castle doctrine was not plain error and that the evidence did not support a finding of self-defense.The Supreme Court of New Jersey reviewed the case, focusing on whether the failure to instruct the jury on the castle doctrine constituted plain error. The Court found that the jury should have been instructed on the exception to the duty to retreat, as there was evidence suggesting the apartment could be considered Bragg's dwelling and conflicting testimony on who the initial aggressor was. The Court held that the failure to provide this instruction was capable of producing an unjust result and constituted plain error.The Supreme Court of New Jersey reversed the Appellate Division's judgment, vacated Bragg's convictions on counts involving self-defense, and remanded the case for further proceedings. The other counts of conviction, for which self-defense was not a possible defense, remained intact. View "State v. Bragg" on Justia Law

In 1991, Celestine Payne poisoned her husband, Alphonso, to collect his life insurance policy. She then enlisted her children and a tenant, Eugene Cooper, to help dispose of Alphonso’s body. Two years later, Celestine convinced Cooper to name her the beneficiary of his life insurance policy and then orchestrated an attack on him. When Cooper survived, Celestine went to the hospital, pretended to be his mother, and signed a do-not-resuscitate order. Celestine also fraudulently obtained a life insurance policy on 18-year-old Tara Carter, naming herself as the beneficiary, and later had Tara bludgeoned to death by Charles Pinchom.In 1997, Celestine pled guilty to multiple charges, including two counts of first-degree murder, and was sentenced to two concurrent life terms plus a consecutive 20-year term. In November 2021, Celestine petitioned for compassionate release under the Compassionate Release Act (CRA), citing her permanent physical incapacity. The trial court found she met the Act’s medical and public safety requirements but denied her petition, citing the particularly heinous, cruel, and depraved nature of her crimes as extraordinary aggravating factors.The Appellate Division reversed the trial court’s decision, holding that the facts of the case did not rise to the level of extraordinary circumstances required to deny compassionate release. The court found that the trial court had abused its discretion in its application of the extraordinary aggravating factors.The Supreme Court of New Jersey reviewed the case and held that the trial court’s finding that Celestine’s crimes were extraordinarily heinous, cruel, and depraved was supported by substantial evidence. The Supreme Court found no abuse of discretion in the trial court’s application of the extraordinary aggravating factors and reversed the Appellate Division’s judgment, reinstating the trial court’s denial of compassionate release. View "State v. C.P." on Justia Law

In August 2018, Thomas Zingis was charged with careless driving and driving while under the influence (DWI). He had a prior DWI conviction from April 2012. In December 2018, the municipal court found Zingis guilty of DWI and sentenced him as a second offender, based on his 2012 conviction. Zingis argued that his first conviction should be disregarded because the State failed to prove it was not based on a Dennis-calibrated Alcotest, referencing the State v. Cassidy decision. The municipal court accepted the prosecutor's representation that Camden was not affected by Dennis's misconduct and sentenced Zingis as a second offender.On appeal, the Law Division also found Zingis guilty and upheld the second-offender sentence. However, the Appellate Division affirmed the conviction but vacated the enhanced sentence, ruling that the State failed to prove beyond a reasonable doubt that Zingis’s 2012 conviction was not based on an inadmissible Alcohol Influence Report (AIR). The case was remanded to a Special Adjudicator to determine which counties were affected by Dennis’s conduct and what notification was provided to affected defendants.The New Jersey Supreme Court reviewed the case and adopted the Special Adjudicator’s findings with modifications. The Court held that in any case where the State seeks an enhanced sentence based on a prior DWI conviction during the period of Dennis’s misconduct, the State must provide discovery to the defendant, including data from Exhibit S-152 and the Dennis Calibration Repository. If the prior conviction involved a Dennis-calibrated Alcotest, the defendant must be given the opportunity to challenge the conviction through post-conviction relief (PCR). The Court also ordered that Exhibit S-152, redacted to exclude personal identifiers, be made publicly available. The judgment of the Appellate Division was affirmed, and the case was remanded to the municipal court for further proceedings consistent with the opinion. View "State v. Zingis" on Justia Law