State of New Jersey v. Manuel P. Rodriguez
A-0539-23
N.J. Super. Ct. App. Div.Jun 2, 2025Background
- Manuel P. Rodriguez was convicted of attempted murder and weapons offenses for shooting victim Tanya Quiles in Newark, New Jersey in 2013.
- The victim identified Rodriguez as the shooter, both during police investigation and at trial; she knew him by his street name "Pito" and recognized his brother Jenssy.
- Rodriguez was convicted after a joint trial with his brother, who was acquitted; Rodriguez did not present any evidence or testify at trial.
- Rodriguez later filed a petition for post-conviction relief (PCR), alleging ineffective assistance of counsel for failing to present alibi witnesses and to litigate a challenge (Wade motion) to the victim's photo identification.
- After an evidentiary hearing (with testimony from defense counsel and alibi witnesses), the trial court denied the PCR, finding counsel was not ineffective.
- The Appellate Division affirmed, deferring to the factual findings of the PCR judge and agreeing that no prejudice was shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance—alibi witnesses | No duty to present perjured testimony | Counsel failed to investigate and call alibi witnesses | Counsel not ineffective; no error |
| Ineffective assistance—photo ID challenge | Decision was a reasonable strategy | Counsel failed to litigate unduly suggestive identification | Strategic, not deficient performance |
| Prejudice from counsel's performance | Evidence against was overwhelming | Would have changed outcome if handled properly | No reasonable probability of change |
| Duty to communicate with defendant | Counsel acted diligently | Counsel pressured guilty plea, did not consult adequately | No evidence of improper pressure |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishing two-prong test for ineffective assistance of counsel)
- State v. Fritz, 105 N.J. 42 (N.J. 1987) (New Jersey adopts Strickland standard for ineffective assistance)
- State v. Nash, 212 N.J. 518 (N.J. 2013) (appellate deference to post-conviction factual findings)
- State v. Pierre, 223 N.J. 560 (N.J. 2015) (deference to trial court on credibility determinations at PCR hearing)
- State v. Robinson, 200 N.J. 1 (N.J. 2009) (role of appellate review over factual findings)