State of New Jersey v. Heather Reynolds, A-1295-22

Heather Reynolds was convicted by a New Jersey jury of murder, child endangerment, and drug possession stemming from the death of her seventeen-month-old son, Abel, in May 2018.
The prosecution relied on forensic evidence and witness testimony to show the child died of asphyxia through a wipe containing isopropyl alcohol and detergent forcibly placed over his mouth and nose.
Reynolds contended that her boyfriend, Caruso, could have been responsible, but evidence (including cell phone data) indicated Caruso had left the residence before Abel’s death.
At trial, witnesses described Reynolds’ emotional demeanor upon discovering Abel’s body as “not genuine.”
Reynolds appealed, arguing the trial court improperly admitted lay opinions about her credibility and emotional state, and that the prosecutor committed misconduct during summation.
The appellate court reviewed evidentiary and prosecutorial conduct issues for plain error given the lack of objection at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of lay witness opinion	Testimony based on personal observation, allowed	Lay opinions unfairly undermined her credibility	Admitted testimony permissible under N.J.R.E. 602 & 701
Prosecutorial misconduct—denigrating defense	Summation proper, based on evidence and in response	Prosecutor denigrated defense, called her a liar	No prosecutorial misconduct; remarks proper
Prosecutorial misconduct—personal belief	Comments were fair, responsive to defense’s theory	Stated only defendant could have committed crime	Proper summation, not improper personal opinion
Cumulative effect of errors	No cumulative prejudice	Combined errors denied fair trial	No cumulative error; affirmed convictions

State v. Garcia, 245 N.J. 412 (deference to trial court’s evidentiary rulings unless clear error)
State v. Scott, 229 N.J. 469 (plain error review standard – error must be clearly capable of producing unjust result)
State v. Risden, 56 N.J. 27 (lay opinions on demeanor admissible if rationally based on perception)
State v. Smith, 212 N.J. 365 (appellate review of prosecutor misconduct is plenary and de novo)
State v. Tucker, 190 N.J. 183 (State may impeach defendant’s inconsistent statements)
State v. Wakefield, 190 N.J. 397 (improper for prosecutors to use derogatory epithets)