Justia Constitutional Law Opinion Summaries

In July 2001, victim C.S. was sexually assaulted by an unknown assailant. The New Jersey State Police Lab (“Lab”) created a profile for the suspect’s DNA sample, Specimen 12A, retrieved from C.S.’s body. In 2002, the Lab entered the DNA profile into the national Combined DNA Index System (“CODIS”). The DNA profile in CODIS did not include certain exclusionary data; without that data, it would have been impossible for Specimen 12A to generate a match with another DNA profile entered into CODIS. In 2004, defendant Bradley Thompson’s DNA sample was collected in an unrelated matter and his DNA profile entered into CODIS in 2006. In 2010, the FBI updated the National DNA Index System (“NDIS”) Operational Procedures Manual to explicitly allow the exclusionary data withheld from Specimen 12A to be entered into the system. In 2016, the Lab entered the exclusionary data for Specimen 12A into CODIS and was alerted that the specimen matched defendant’s DNA sample that had been entered into CODIS years earlier. Based on that match, defendant was indicted in May 2017 for offenses related to the July 2001 sexual assault. Defendant moved to dismiss, arguing that the five-year statute of limitations began to run in 2004, when the State possessed both the physical evidence from the crime and defendant’s DNA sample. The trial court denied his motion and concluded that the statute of limitations started running when the State had evidence of a match. Defendant was ultimately convicted of fourth-degree criminal sexual contact and fourth-degree criminal trespass. The Appellate Division affirmed defendant’s conviction, finding that the statute of limitations began to run in 2016 when the State received a DNA match. The New Jersey Supreme Court reversed, finding the statute of limitations began to run in 2010, when the FBI’s updated scientific guidance rendered the Lab capable of generating a match based on the DNA samples in its possession. View "New Jersey v. Thompson" on Justia Law

In this appeal, a detective administered Miranda warnings but repeatedly undermined them throughout an interrogation. The New Jersey Supreme Court concluded the detective here repeatedly contradicted and minimized the significance of the Miranda warnings -- starting at the outset of the interrogation and continuing throughout -- meaning the State could not prove beyond a reasonable doubt, that defendant knowingly, voluntarily and intelligently waived his rights. The Appellate Division concluded defendant's statement made to police in violation of his Miranda rights had to be suppressed, and the Supreme Court affirmed. View "New Jersey v. O.D.A.-C." on Justia Law

A car driven by defendant Rashaun Bell crashed into two teenaged boys riding a bicycle on a roadway in Jersey City. Both boys died as a result of the accident. Defendant and his three passengers fled the scene. Defendant was eventually apprehended and indicted on two counts of leaving the scene of an accident; he moved to dismiss one of the counts, arguing that, as applied here, N.J.S.A. 2C:11-5.1 violated the rule against multiplicity. The trial court denied defendant’s motion and concluded N.J.S.A. 2C:11-5.1 holds a driver who knowingly flees the scene of an accident criminally responsible for each person who dies in the accident. Defendant thereafter pled guilty, pursuant to a plea agreement as to both counts of the indictment. Consistent with the agreement, the trial court sentenced defendant to two consecutive five-year terms of imprisonment. In response to defendant’s appeal, the Appellate Division reversed the trial court’s ruling, dismissed one of the convictions, vacated the five-year term of imprisonment for that conviction, and remanded the matter to the trial court to amend the judgment of conviction accordingly. The New Jersey Supreme Court held that the number of fatalities caused by the accident was not an element of the second-degree offense codified in N.J.S.A. 2C:11-5.1. Therefore, the Court affirmed the part of the Appellate Division's judgment, but reversed with respect to that court's sua sponte amendment to defendant's sentence, "in a manner not contemplated by the terms of the plea agreement negotiated by the parties in good faith and approved by the trial court under Rule 3:9-2. Under these circumstances, the appellate court should have remanded the case to the trial court to permit the parties to negotiate a new plea agreement that the trial court finds acceptable or otherwise schedule the case for trial." View "New Jersey v. Bell" on Justia Law

Defendant Anthony Sims, Jr. challenged his conviction of attempted murder and weapons offenses arising from the April 9, 2014 shooting of P.V. One of the issues this case presented for the New Jersey Supreme Court's review centered on the Appellate Division majority’s holding that police officers, prior to interrogation, were required to inform an arrestee of the charges that will be filed against him, even when no complaint or arrest warrant has been issued identifying those charges. Here, the divided panel found that the police officers who interrogated defendant violated his Miranda rights by not providing that information. Further, this case presented the issue of whether the trial court’s decision to admit at trial P.V.’s prior testimony at a pretrial hearing violated the rule against hearsay and the Confrontation Clause. P.V. was indicted for the murder of defendant’s brother. Although offered an immunity agreement by the State and ordered to testify by the trial court, P.V. asserted his Fifth Amendment privilege not to testify. The trial court permitted the State to present at trial P.V.’s testimony at the Wade/Henderson hearing as the prior testimony of an unavailable witness. The Appellate Division vacated defendant’s convictions and remanded for a new trial. A divided panel held that the police officers who interrogated defendant violated his Miranda rights. The court unanimously held that the trial court’s decision to admit at trial P.V.’s prior testimony violated the rule against hearsay and the Confrontation Clause. The Supreme Court declined to adopt the Appellate Division's analysis, and found no plain error in the trial court’s denial of defendant’s motion to suppress his statement to police. The Court also concurred with the trial court that the victim’s testimony at the pretrial hearing was admissible under N.J.R.E. 804(b)(1)(A)’s exception to the hearsay rule for the prior testimony of a witness unavailable at trial, and that the admission of that testimony did not violate defendant’s confrontation rights. View "New Jersey v. Sims" on Justia Law

Plaintiff Kathleen Moynihan and defendant Edward Lynch were involved in a long-term “marital-style relationship.” Anticipating the potential dissolution of that relationship, they signed and notarized a written agreement, without the assistance of counsel, that finalized the financial obligations each owed to the other. The issue this case presented for the New Jersey Supreme Court's review was the validity of that palimony agreement. In 2015, the parties parted ways, and Lynch refused to abide by their written agreement. Moynihan filed a complaint seeking enforcement of the written agreement and an alleged oral palimony agreement that she claimed the parties had entered before the Legislature in 2010 amended N.J.S.A. 25:1-5 to include subparagraph (h), which mandated that palimony agreements be reduced to writing and “made with the independent advice of counsel.” She challenged N.J.S.A. 25:1-5(h) on constitutional grounds and urged enforcement as a typical contract; alternatively, she sought enforcement of the agreement on equitable grounds. Lynch denied the existence of an oral palimony agreement and asserted that the written agreement was unenforceable because the parties did not receive the independent advice of counsel before entering it. The Supreme Court concluded the palimony agreement, as written and signed, without the attorney review requirement, was enforceable. That portion of N.J.S.A. 25:1-5(h), which imposed an attorney-review requirement to enforce a palimony agreement, contravenes Article I, Paragraph 1 of the New Jersey Constitution. The Court concluded the parties did not enter an oral palimony agreement. View "Moynihan v. Lynch" on Justia Law

In October 2017, an incarcerated woman filed a lawsuit against Cumberland County and several corrections officers, including Tyrone Ellis, alleging she had been forced to engage in non-consensual sex acts on a regular basis. Plaintiff Libertarians for Transparent Government (Libertarians) obtained minutes of the public meeting of the Board of the Police and Firemen’s Retirement System at which the Board considered Ellis’s application for special retirement. According to the minutes, the County originally sought to terminate Ellis, who had been charged with a disciplinary infraction. When he submitted his resignation, the County warned that it intended to continue to prosecute the disciplinary matter. Ellis, in turn, “agreed to cooperate” with the County’s investigation of four other officers suspected of similar misconduct. “As a result of his cooperation, Cumberland County agreed to dismiss the disciplinary charges and permit Mr. Ellis to retire in good standing” with a reduced pension. Libertarians sent the County an OPRA request seeking, as relevant here, the settlement agreement and Ellis’s “'name, title, position, salary, length of service, date of separation and the reason therefor’ in accordance with N.J.S.A. 47:1A-10.” The County declined to produce the settlement agreement, claiming it was a personnel record exempt from disclosure. In response to the request for information, the County stated in part that “Officer Ellis was charged with a disciplinary infraction and was terminated.” Libertarians filed a complaint in Superior Court, and the trial court ordered the County to provide a redacted version of the settlement agreement. The County appealed, and the Appellate Division reversed the trial court’s judgment. The New Jersey Supreme Court concluded the trial court properly ordered disclosure of a redacted settlement agreement, and the Appellate Division reversed. The Supreme Court reinstated the trial court’s order. View "Libertarians for Transparent Government v. Cumberland County" on Justia Law

In winter 1996, defendant Samuel Ryan (then aged 23) robbed a Bridgeton, New Jersey gas station at gunpoint, stealing $100 and shooting a store clerk in the process. The offense resulted in defendant’s third first-degree robbery conviction, and he was sentenced to life in prison without parole pursuant to the Persistent Offender Accountability Act, known as the “Three Strikes Law.” In this appeal, defendant contended the Three Strikes Law violated the prohibition against cruel and unusual punishment contained in the Eighth Amendment of the United States Constitution and Article I, Paragraph 12 of the New Jersey Constitution. He alleged that, by allowing courts to count crimes committed while under the age of eighteen as predicate offenses in sentencing defendants to mandatory life without parole, the Three Strikes Law ignored the constitutional constraints embodied in Miller v. Alabama, 567 U.S. 460 (2012), and New Jersey v. Zuber, 227 N.J. 422 (2017), which prohibited imposition of mandatory life-without-parole sentences or their functional equivalent on juvenile offenders. The New Jersey Supreme Court found that because defendant committed his third offense and received an enhanced sentence of life without parole as an adult, this appeal did not implicate Miller or Zuber. Accordingly, defendant’s sentence was affirmed and the Court reaffirmed the constitutionality of the Three Strikes Law. View "New Jersey v. Ryan" on Justia Law

This matter involved a legal challenge to the congressional redistricting map selected by the New Jersey Congressional Redistricting Commission (Commission). On December 22, 2021, a majority of the Commission’s members that included the Chair, voted in favor of the map the Democratic delegation presented. Plaintiffs, the Republican delegation to the Commission, filed an amended complaint on January 5, 2022 to challenge that map. Plaintiffs filed their complaint directly with the New Jersey Supreme Court, pursuant to Article II, Section 2, Paragraph 7 of the New Jersey Constitution. The Supreme Court observed it had no role in the outcome of the redistricting process unless the map is "unlawful." The Supreme Court found none of plaintiffs' arguments asserted the plan was unlawful or the result of "invidious discrimination." Because plaintiffs’ allegations were insufficient to support a claim upon which relief can be granted, defendants’ motion to dismiss the complaint with prejudice was granted. View "In the Matter of Establishment of Congressional Districts by the New Jersey Redistricting Commission" on Justia Law

In 2017, police questioned defendant Laura Gonzalez -- after providing her with her Miranda warnings -- in connection with the discovery that the infant for whom she served as a nanny had two fractures in his right leg and one in his left. In the middle of the interview, defendant asked, “But now what do I do about an attorney and everything?” Rather than seek clarification, the interviewing detective merely advised defendant, “That is your decision. I can’t give you an opinion about anything.” Ultimately, defendant admitted to abusing the child and, at the interviewing detective’s suggestion, wrote his parents an apology note. Defendant was charged with endangerment and aggravated assault. She moved to suppress portions of her statement and the note, arguing that she invoked her right to counsel during her interview. The trial court denied defendant’s motion, reasoning that defendant’s statement did not rise to the level of being an assertion of her right to counsel -- not even an ambiguous assertion of that right, which would have triggered a duty for the interviewing officer to seek clarification under New Jersey law. The New Jersey Supreme Court reversed the judgment of the Appellate Division and remanded the matter for further proceedings. The Supreme Court concluded defendant’s question about the attorney was an ambiguous invocation of her right to counsel and that, under settled New Jersey law, the detective was required to cease questioning and clarify whether defendant was requesting counsel during the interview. "And, because the State played defendant’s recorded statement at trial and read the apology note -- written at the detective’s suggestion -- to the jury," the Court found the error to be harmful. View "New Jersey v. Gonzalez" on Justia Law

While surveilling a street corner in Newark, two detectives observed several men loitering in the area. A detective testified that one of the individuals, later identified as defendant Tywaun Hedgespeth, adjusted his clothes, at which point officers saw what looked like the butt of a gun. Backup units were told to apprehend the men and to be cautious with defendant. A detective apprehended defendant, ordered him to show his hands, took him to the ground, and then alerted fellow officers that he found a weapon. Defendant was searched by the arresting officers who discovered crack cocaine on his person. No fingerprints were found on the gun. Defendant went to trial on a drug possession charge and an unlawful possession of a weapon charge. The jury found defendant guilty on both counts, and he pleaded guilty to a certain-persons offense the same day. The Appellate Division affirmed defendant’s convictions. Defendant appealed, arguing: (1) the trial court committed harmful error in permitting impeachment of defendant by his prior convictions; and (2) the trial court erred in admitting an affidavit by a non-testifying officer. The New Jersey Supreme Court concluded after review of the record that the trial court erred in allowing the State to enter into evidence information set forth in the affidavit of a non-testifying officer concerning the no-permit results from a search of the State firearm registry, and that violation was not cured by testimony concerning the search of an Essex County firearm database. Further, the trial court’s incorrect N.J.R.E. 609 ruling constituted harmful error requiring reversal of the conviction. However, the Court declined to adopt the position that an evidentiary ruling that results in a defendant’s decision not to testify can never be harmless. Accordingly, the judgment of the Appellate Division was reversed. View "New Jersey v. Hedgespeth" on Justia Law