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State v. Watson

New Jersey Appellate Division

June 8, 2022

The New Jersey Appellate Division concluded its 166-page opinion by stating that “to the extent we have not addressed them, any additional arguments raised by defendant lack sufficient merit to warrant discussion in this opinion.” The arguments the Court reviewed were critical criminal law issues. First, the Court held that the trial court violated the defendant’s confrontation rights by permitting testimony that the investigating police agency consulted with another police department before filing criminal charges. But the Court ruled that it was harmless error. Second, the Appellate Division concluded that the trial court did not abuse its discretion by allowing a police witness to narrate surveillance video as it was being played to the jury. Third, the Court rejected the defendant’s contention that the trial court erred by allowing a witness to make an in-court identification after having selected the photograph of another person from a photo array. Fourth, the Court rejected the defendant’s complaints that the lower court erred by reading the model jury instructions for some portions and further erred by failing to tailor other sections appropriately. But all parties agreed that the trial court did not make a finding on the defendant’s ability to pay restitution. Thus, the Appellate Division reversed the restitution order and remanded for an ability-to-pay hearing.

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