State of New Jersey v. Anthony Reciofigueroa, A-0692-22

Defendant Anthony Reciofigueroa was convicted of first-degree murder and related weapons offenses after the 2019 shooting death of C.R. in Elizabeth, New Jersey.
No eyewitnesses saw the shooting, and the murder weapon was never recovered; the prosecution's case relied heavily on circumstantial evidence, particularly police-narrated surveillance footage from nearby cameras, none of which captured the shooting itself.
Det. Sonia Rodriguez, based on her review of video evidence, repeatedly identified Reciofigueroa as the shooter and described the vehicle and route allegedly used.
Defense argued another individual, Dave (D.P.), may have been the shooter, as he also had access to the vehicle of interest, yet the jury was not instructed on a third-party guilt defense.
The jury convicted Reciofigueroa, who was sentenced to 55 years in prison; he appealed, primarily citing improper video narration and the failure to charge third-party guilt.
The Appellate Division found reversible error in the admission of improper opinion testimony and in the lack of a third-party guilt instruction, and vacated the convictions, remanding for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of detective’s video narration testimony	Proper for detective to narrate and ID	Detective lacked firsthand knowledge—improper	Detective testimony was inadmissible opinion; error
Identification of defendant in surveillance footage	Detective could identify subject	Only jury should decide; ID was disputed	Detective’s opinion invaded jury’s role; error
Jury instruction on third-party guilt (re Dave)	No instruction needed; evidence strong	Evidence pointed to another possible shooter (Dave)	Failure to instruct was plain error
Cumulative impact of evidentiary and instruction errors	Errors do not justify reversal	Combined errors denied fair trial	Errors deprived defendant of fair trial; reversal

State v. Watson, 254 N.J. 558 (2023) (set standards for narrating video evidence by officers based only on their review, not firsthand observation)
State v. Singh, 245 N.J. 1 (2021) (clarified requirements for video narration and opinion testimony by investigators)
State v. Reddish, 181 N.J. 553 (2004) (trial courts must ensure jury receives proper instructions on applicable law)
State v. Collier, 90 N.J. 117 (1982) (incomplete jury charges can be reversible error)
State v. Jenewicz, 193 N.J. 440 (2008) (cumulative error analysis can justify a new trial)
State v. Burney, 255 N.J. 1 (2023) (cumulative error must render the trial unfair for reversal to be granted)