State in the Interest of N.H.(076316)
141 A.3d 1178
| N.J. | 2016Background
- In June 2014 a fight among high‑school students resulted in one student’s death; respondent juvenile (N.H.), 17, was accused of grabbing a handgun and shooting the victim.
- N.H. was charged in the Family Part with acts that, if by an adult, would constitute murder and related firearms offenses; the State moved to waive juvenile jurisdiction and transfer the matter to adult criminal court.
- The State produced some materials (incident report, recorded statements, surveillance video, autopsy, etc.) but withheld other witness statements, police reports, and additional videos it said it would not use at the waiver hearing.
- N.H. moved for full pre‑waiver discovery; the trial court granted the motion and the Appellate Division affirmed. The State appealed to the New Jersey Supreme Court.
- The Supreme Court addressed whether, when the State seeks waiver to adult court, the juvenile is entitled to full discovery of materials in the State’s possession (subject to protective orders).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a juvenile is entitled to full discovery when the State seeks waiver to adult court | N.H.: filing of a juvenile complaint is equivalent to an indictment; full discovery must be provided before the waiver hearing | State: disclose only what it will introduce plus any exculpatory evidence; full discovery so early would delay cases and jeopardize investigations | Court: State must disclose all discovery in its possession soon after it seeks waiver, subject to protective orders |
| Scope of the waiver‑hearing review of the prosecutor’s decision | N.H.: waiver hearing is critical and requires materials to challenge prosecutor’s exercise of discretion | State: hearing is primarily probable cause; full discovery unnecessary before judge rules on waiver | Court: hearing requires review for abuse of prosecutorial discretion under statute; discovery needed to assess that review |
| Whether Family Part or adult discovery rules govern juvenile waiver proceedings | N.H.: analogize to adult criminal discovery rules for full disclosure | State: juvenile rules and practice can limit discovery prior to waiver | Court: Part V refers juvenile practice to Part III; supervisory power used to require disclosure consistent with Rule 3:13 practices |
| Whether protective orders are available to the State | N.H.: full disclosure subject to legitimate protective limits | State: requests ability to withhold information for safety/investigative reasons | Court: protective orders may be granted to redact, delay, or withhold material that would harm witnesses, ongoing investigations, or other legitimate interests |
Key Cases Cited
- State v. R.G.D., 108 N.J. 1 (1987) (waiver to adult court is the most serious juvenile‑court action)
- State in Interest of K.A.W., 104 N.J. 112 (1986) (practice of State "opening its file" to juveniles despite absence of rule)
- J.M. v. State, 182 N.J. 402 (2005) (prosecutor must file a statement of reasons for waiver; courts review for abuse of discretion)
- Kent v. United States, 383 U.S. 541 (1966) (due process requires hearing, counsel, and access to relevant records at juvenile waiver stage)
- State in Interest of A.B., 219 N.J. 542 (2014) (scope of automatic discovery tied to materials in State’s possession, custody or control)
- State in Interest of V.A., 212 N.J. 1 (2012) (interpretation of waiver statute and review for abuse of discretion)
- State ex rel. P.M.P., 200 N.J. 166 (2009) (filing a juvenile complaint and issuing an arrest warrant constitutes a critical stage implicating right to counsel)