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

A former Newark policeman, Keith Isaac, applied for special retirement in 2013, listing his estranged spouse, Roxanne, as his wife on the application. His retirement was approved in 2016, retroactive to August 1, 2014, resulting in $208,950.03 in unpaid benefits. Isaac passed away before receiving these benefits, and the Division of Pensions and Benefits distributed the unpaid benefits to Roxanne in March 2017. Isaac’s estate requested reconsideration, arguing that the benefits should be paid to the estate. The Board of Trustees of the Police and Firemen’s Retirement System (PFRS) upheld the decision, stating that Isaac had designated Roxanne as his beneficiary.The estate appealed to the Office of Administrative Law (OAL), which affirmed the Board’s decision, reasoning that listing Roxanne as his spouse on the retirement application constituted a beneficiary designation. The estate then appealed to the Appellate Division, which remanded the case to the OAL for a supplemental hearing to determine Isaac’s probable intent regarding the unpaid benefits.The Supreme Court of New Jersey reviewed the case and held that N.J.S.A. 43:16A-12.2 mandates that unpaid benefits be distributed to the decedent’s estate unless a beneficiary is nominated by written designation. Since Isaac did not make such a designation, the Court ruled that the Board’s decision to distribute the benefits to Roxanne was arbitrary, capricious, and unreasonable. The Court reversed the Appellate Division’s decision to remand for further fact-finding and directed that the $208,950.03 in unpaid benefits be distributed to Isaac’s estate. View "Isaac v. Board of Trustees, Police and Firemen's Retirement System" 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 New Jersey Coalition of Automotive Retailers (NJCAR), a trade association representing franchised new car and truck retailers in New Jersey, sued Ford Motor Company. NJCAR alleged that Ford's Lincoln Commitment Program (LCP) violated the Franchise Practices Act (FPA) by creating price differentials among franchisees. NJCAR is not a franchisee itself but represents franchisee members, including Lincoln dealerships.The trial court granted summary judgment in favor of Ford, ruling that NJCAR lacked statutory standing to sue under the FPA because the statute limits the right to sue to franchisees. NJCAR appealed, arguing that it had associational standing to represent its members. The Appellate Division reversed the trial court's decision, holding that NJCAR had associational standing and that New Jersey's liberal standing doctrine did not preclude NJCAR from bringing the suit.The Supreme Court of New Jersey reviewed the case and reversed the Appellate Division's decision. The Court held that the FPA explicitly limits the right to bring a lawsuit to franchisees, as indicated by the statute's language stating that "any franchisee may bring an action against its franchisor." The Court emphasized that the Legislature's intent was clear in restricting the right to sue to franchisees only, and NJCAR, not being a franchisee, lacked statutory standing to bring the suit under the FPA. The Court did not address whether NJCAR would have associational standing under a different cause of action, limiting its holding solely to the FPA. View "New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company" on Justia Law

M.R., an inmate serving a prison sentence for racketeering, experienced significant health issues, including balance problems and difficulty writing. In August 2020, he was diagnosed with a malignant brain tumor and underwent surgery in January 2021. By November 2022, M.R. was wheelchair-bound with residual neurological deficits. In February 2023, M.R. applied for compassionate release under the Compassionate Release Act (CRA). The New Jersey Department of Corrections (DOC) designated two physicians to review his medical records, who provided conflicting diagnoses regarding his terminal condition status. The DOC ultimately denied M.R. a Certificate of Eligibility for compassionate release.M.R. appealed the DOC's decision, and in August 2023, the Appellate Division remanded the case for reevaluation due to the conflicting medical opinions. The physicians provided updated reports, now uniformly concluding that M.R. did not suffer from a terminal condition or permanent physical incapacity, again relying solely on M.R.'s electronic medical records. The DOC reaffirmed its denial of the Certificate of Eligibility. The Appellate Division later affirmed the DOC's decision, concluding that the CRA does not require physical examinations and that the denial was not arbitrary, capricious, or unreasonable.The Supreme Court of New Jersey reviewed the case, focusing on whether the CRA and its implementing regulation require physical examinations for compassionate release applications. The Court held that the CRA does not mandate physical examinations for medical diagnoses. However, the Court found the DOC's decision to deny M.R. a Certificate of Eligibility in August 2023 to be arbitrary, capricious, and unreasonable. The Court emphasized the need for contemporaneous and comprehensive medical evaluations to support such decisions and reversed the Appellate Division's judgment. View "M.R. v. New Jersey Department of Corrections" 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 this case, the Attorney General of New Jersey decided to supersede control of the Paterson Police Department following a fatal police shooting. The Attorney General appointed Isa M. Abbassi, a veteran NYPD officer, as the Officer in Charge (OIC) and reassigned the Paterson Police Chief, Engelbert Ribeiro, to the Police Training Commission in Trenton. Plaintiffs, including Paterson officials, challenged the Attorney General's authority to supersede the police department without local consent.The case was first brought to the Law Division, which transferred it to the Appellate Division. The Appellate Division consolidated the actions and ultimately reversed the Attorney General's decision, ruling that the Attorney General exceeded his statutory powers. The appellate court directed the defendants to reassign Ribeiro to Paterson, relinquish control of the department to city officials, and provide a report summarizing their actions and expenditures during the supersession.The New Jersey Supreme Court reviewed the case and found evidence that the Legislature intended to authorize the supersession in two statutes: Chapter 94, which facilitated the OIC's leadership, and the appropriations bill for the fiscal year ending June 30, 2024, which funded the Attorney General's operation of the department. The Court did not base its holding on other statutes or authorities cited by the defendants. The Court reversed the Appellate Division's judgment, finding that the Attorney General's supersession of the Paterson Police Department was not arbitrary, capricious, or unreasonable, and had fair support in the record. The Court did not address whether the Attorney General has general authority to supersede municipal police departments in other circumstances. View "Bulur v. The New Jersey Office of the Attorney General" 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