State of New Jersey v. Jomo K. Lylesbelton, A-3984-22

Jomo K. Lylesbelton was convicted by a jury in New Jersey of possessing cocaine with intent to distribute and possessing a firearm during a drug offense, after law enforcement found drugs and a handgun in his bedroom during a warranted search.
At trial, some cocaine evidence introduced (exhibit S-2) mistakenly included baggies from unrelated controlled buys. The error was realized during a witness’s testimony.
The trial court issued immediate curative instructions to the jury, telling them to disregard the erroneous evidence and excluded the related testimony, but denied a defense motion for a mistrial.
The lead detective, DiValerio, did not personally find the drugs but testified about receiving and securing the evidence, raising questions of hearsay and confrontation rights addressed at trial and appeal.
Lylesbelton appealed his conviction, arguing evidentiary error, confrontation and hearsay violations, prejudicial error from the inadvertent evidence, improper jury instructions, and a Second Amendment challenge to the statutory offense.
The Appellate Division affirmed the convictions and sentences, finding no abuse of discretion or injustice in admitting the evidence or in the management of trial errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of Evidence (Chain of Custody, Hearsay, Confront.)	Officer’s custody and testimony satisfied rules.	No direct, personal knowledge; improper hearsay.	Admission proper; no abuse of discretion.
Mistrial re: Inadvertently Admitted Extra Bags	Curative instructions sufficient to cure prejudice.	Still prejudicial, should require mistrial.	Curative instructions adequate; mistrial not warranted.
Jury Instructions on Firearm During Drug Offense (Spivey)	Model jury charge sufficiently set forth law.	Instructions failed to explain necessary legal nexus.	Instructions adequate; no plain error; affirmed.
Second Amendment Challenge to N.J.S.A. 2C:39-4.1(a)	--	Statute violated his Second Amendment rights.	Argument not considered—raised for first time on appeal.

State v. Morton, 155 N.J. 383 (Chain of custody need not be perfect; defect affects weight, not admissibility)
State v. Spivey, 179 N.J. 229 (Jury must find linkage between firearm and drugs for firearm/drug offense)
State v. Herbert, 457 N.J. Super. 490 (Curative instructions assessed for prejudice, timing, and compliance)
State v. Winter, 96 N.J. 640 (Denial of mistrial reviewed for abuse of discretion; curative instructions generally favored)
Phillips v. Gelpke, 190 N.J. 580 (Lay witness testimony requires only personal knowledge foundation)
State v. Brunson, 132 N.J. 377 (Authentication/admissibility requires reasonable probability of unaltered evidence)