In re Reddin
111 A.3d 74
N.J.2015Background
- Two sitting New Jersey judges, Raymond Reddin and Gerald Keegan, were investigated for dining publicly with Anthony Ardis, an individual indicted for official misconduct, in the courthouse vicinity.
- ACJC found the dinners violated Canons 1, 2A, and 5A(2) by creating an appearance of impropriety that could undermine public confidence in the judiciary.
- Respondents stopped attending the dinners once the grievance was filed and cooperated with the investigation.
- This matter revises the test for appearance of impropriety from a purely subjective standard to an objective-plus-subjective standard, focusing on reasonable perception.
- Court declines to impose sanctions, but stresses the new standard applies going forward and notes the need for judges to avoid public socializing with individuals under indictment in advance of trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What standard governs appearance of impropriety for judges' personal conduct? | Presenter supported Blackman; standard should rely on fair public concern. | Reddin/Keegan urged DeNike-style objective reasonableness. | Court adopts objective-reasonableness standard. |
| Did the judges' public dinners with a defendant under indictment create an appearance of impropriety? | Yes; socializing with an indicted defendant undermines integrity and impartiality. | No; no improper motive, no discussion of case, no sanction warranted. | Yes; violated Canons 1, 2A, and 5A(2); no sanctions imposed. |
| Should sanctions be imposed given the new standard? | Discipline would be appropriate under the objective standard. | No sanctions warranted given unblemished record and cooperation. | No sanctions imposed; guidance for future application of the standard given. |
Key Cases Cited
- In re Blackman, 124 N.J. 547 (1991) (appearance of impropriety standard)
- In re Rodriguez, 196 N.J. 450 (2008) (public admonition for mayor’s house incident)
- DeNike v. State, 196 N.J. 506 (2008) (reasonable, fully informed doubts about impartiality)
- In re Seaman, 133 N.J. 67 (1993) (discipline standard; appearance of impropriety context)
- Offutt v. United States, 348 U.S. 11 (1954) (appearance of justice principle)