Kidnapping and Jury Verdict Sheets (Part 5)

by | Oct 21, 2019 | Blog, Criminal Law, Monmouth County, New Jersey, Ocean County

Justice Patterson continued in relevant part: Our concurring and dissenting colleague asserts two arguments in support of the contention that the error in the verdict sheet warrants reversal of defendant’s first-degree kidnapping convictions. First, our dissenting colleague surmises that the jury’s generic question to the trial court — “if applicable, how do we denote second degree on a charge in the verdict book?” — related to the two first-degree charges for which the jury convicted defendant, not to the other sixteen first-degree charges that the jury considered. Post at ___ (slip op. at 3). Second, our dissenting colleague argues that, in our harmless error analysis, we have considered an argument that was not properly raised by the State and have displaced the jury in the role of factfinder. Post at ___ (slip op. at 6). Neither contention has merit.

When it asked the trial court about how to “denote” a second-degree charge, the jury had before it a verdict sheet requiring it to answer 115 questions, 62 of which related to the nineteen first-degree charges pending against defendant. The verdict sheet properly focused on the elements of each offense, and did not use the terms “first-degree” or “second-degree” to categorize the various charges. The jury’s question could have related to any of the first-degree charges — the five on which defendant was convicted, the twelve on which defendant was acquitted, or the one on which defendant was convicted of a lesser-included offense — or to any of the twenty-three second-degree charges. Alternatively, the jury’s question could have pertained to no charge in particular. There is simply no basis for any speculation — let alone our dissenting colleague’s certainty — as to the import of the jury’s question.

We also respectfully disagree with our dissenting colleague’s suggestion that, in our harmless error analysis, we have improperly considered a question that was not before the Court. The dissent contends that we granted certification to consider whether “the verdict sheet and the trial court’s erroneous response to the jury’s question precluded the jury from convicting defendant of second-degree kidnapping.” Post at ___ (slip op. at 5). That quotation is not from the Court’s grant of certification, but from defendant’s brief to the Appellate Division. As framed by the Court, the grant of certification generally related to “the verdict sheet’s omission of the charge of second-degree kidnapping” and the imposition of consecutive sentences. 234 N.J. 315. There is no support for the dissent’s contention that our grant of certification was a “shorthand” for the defendant’s argument. Post at ___ (slip op. at 5).

In holding that “there is no basis for any speculation”, Justice Patterson is at the same time speculating as to what the jury “could have” been doing. Justice Albin, the author of the dissent, has been the lone dissent in favor of the accused in many cases.

Excellent rating
Based on 288 reviews
Google star 1Google star 2Google star 3Google star 4Google star 5
Google star 1Google star 2Google star 3Google star 4Google star 5
Thank you very much for your information on DUI check points. It is a great asset to the community . 5 stars for sure!
James P
Google star 1Google star 2Google star 3Google star 4Google star 5
Not to long ago I ran into a very serious legal issue for the first time in my life, I'm closing in on 60. Needless to say I was unsure of the process. I was fortunate that a friend recommended Fred. Fred handled my case in a professional and courteous manner yet was very down to earth and straight forward. It took nearly 9 month to resolve and during that time Fred was always available to answer questions, explain the process and most of all alleviate my stress. I feel we got the best possible outcome and I would highly recommend Fred to anyone facing a legal/criminal matter
Manny P
Google star 1Google star 2Google star 3Google star 4Google star 5
Great that Fred posts DUI for Monmouth County!
David F
Google star 1Google star 2Google star 3Google star 4Google star 5
I recently utilized his exceptional services and would highly recommend them to anyone seeking legal advice.
Mark A
Google star 1Google star 2Google star 3Google star 4Google star 5
Mr. Fred Sisto is really an amazing attorney! Professional, knowledgeable, and effective. He made me feel comfortable in knowing he was working countless hours on my case to get me the best possible outcome. Mr. Sisto was very responsive and kept me updated with all court proceedings/updates. I am thankful to have had him represent me. I will be recommending Mr. Sisto & his firm to anyone in need. Thanks again ! Much Appreciated
Javier B
Google star 1Google star 2Google star 3Google star 4Google star 5
Called back within 10 minutes,very easy to talk to. Not judgmental at all. I am hopeful about the outcome.
Colleen H
Google star 1Google star 2Google star 3Google star 4Google star 5
Great!!! , got my case handled in the exact manner that I was told and would recommend to everyone else in need of legal representation .
Raumelis R
Google star 1Google star 2Google star 3Google star 4Google star 5
Mr. Sisto was not only a knowledgeable and excellent lawyer, he was compassionate and understanding during this difficult time. I found Mr. Sisto to always be available and he services were affordable and effective. You will not find a better lawyer.
Joseph S
Google star 1Google star 2Google star 3Google star 4Google star 5
Always up to date on with his services.
Anthony L
Google star 1Google star 2Google star 3Google star 4Google star 5
He is the best professional to have on your side taking care of your interests. Your in the best of hands.
Stuart C