In criminal trials, the State is limited as to the evidence it may introduce in support of the allegation that a defendant committed a crime. Specifically, the State generally cannot introduce evidence of prior criminal activity or wrongful acts to prove that a defendant committed the offense with which he or she is currently charged, as it has the potential to lead to unjust results. Recently, a New Jersey appellate court discussed the ramifications of improper prior bad acts evidence and when the admission of such evidence warrants the reversal of a conviction in a case in which the defendant was charged with eluding the police. If you are charged with eluding, it is in your best interest to speak to a seasoned New Jersey criminal defense attorney regarding what evidence the State may introduce against you.
Factual and Procedural History
It is reported that police officers were dispatched to investigate a report that a convenience store had been robbed at gunpoint by a suspect who drove off in a white car. While patrolling the area where the incident allegedly occurred, an officer observed the defendant driving a vehicle that matched the description of the suspect’s vehicle. The officer activated his sirens and lights and followed the defendant for a mile and a half, during which the defendant drove twenty-five miles over the speed limit, veered onto the sidewalk, and crashed into poles. The defendant ultimately crashed into a pole and stopped.
It is alleged that the defendant was charged with eluding the police. A four-day trial was held during which the State introduced into evidence three summons that were previously issued to the defendant, involving reckless driving, driving with a suspended license and operation of a vehicle without a license. The defendant did not object to the admission of the summons and was ultimately convicted. He then appealed.
Reversal Based on Improper Evidence
On appeal, the defendant argued that the trial court erred in admitted evidence of prior bad acts. Specifically, the defendant argued that the summons constituted evidence of unproven and irrelevant bad acts that clearly had the capacity to lead to his conviction, which resulted in a tainted and unjust verdict. In response, the State conceded that the summons were not relevant to the issue of whether the defendant eluded the police and therefore did not satisfy the factors for admission of bad act evidence pursuant to the New Jersey rules of evidence, but argued that the error did not require a reversal of the trial court verdict.
Upon review, the appellate court agreed with the State. Specifically, the appellate court stated that because the defendant did not object to the admission of the evidence at trial, the State’s error would be disregarded unless the defendant demonstrated there was a reasonable doubt the jury would not have reached its verdict absent the inappropriate evidence. The appellate court found that the defendant could not meet this burden, however as the State produced compelling evidence outside of the summons that was sufficient to support the defendant’s conviction. Thus, the court affirmed that trial court’s verdict.
Consult a Skillful Criminal Defense Attorney
People charged with eluding the police have protections against the introduction of inappropriate evidence at trial, including evidence of prior wrongs. If you are charged with eluding, the skillful New Jersey criminal defense attorneys of The Law Offices of Jonathan F. Marshall can assist you by developing compelling arguments in your defense to help you strive for a successful result. We can be reached at 877-450-8301 or through the online form to set up a meeting.