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State of New Jersey v. Wedpens Dorsainvil
435 N.J. Super. 449
| N.J. Super. Ct. App. Div. | 2014
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Background

  • Defendant was charged by indictment with multiple crimes including conspiracy to murder Payne and related offenses.
  • A jury returned verdicts including first degree conspiracy to murder Payne and other lesser-included offenses.
  • The trial court sentenced defendant to 45 years with parole ineligibility and supervision under NERA.
  • On appeal, the Appellate Division found the convictions cannot stand due to a violent incident among jurors during deliberations.
  • A physical altercation occurred between jurors on the second day of deliberations, prompting sheriff’s intervention and concerns about coercion.
  • The court’s subsequent civility instructions and handling of juror issues were criticized as exacerbating coercion; the matter was remanded for new trial.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Was a mistrial required due to juror violence during deliberations? Violence contaminated deliberations; mistrial necessary to preserve justice. The judge could salvaged deliberations with proper procedures and instructions. Mistrial required; reversed and remanded for new trial.
Did the court's civility order and handling of juror issues improperly coerce deliberations? Civility code and ex parte actions coerced jurors and tainted the verdict. Instructions were appropriate to restore order and ensure fairness. Supplemental instructions were coercive; contributed to reversal and remand.

Key Cases Cited

  • State v. Ramseur, 106 N.J. 123 (N.J. 1987) (guides evaluating deliberations and mistrial standards)
  • State v. Figueroa, 190 N.J. 219 (N.J. 2007) (warns against coercive judicial conduct in deadlocked juries)
  • State v. Czachor, 82 N.J. 392 (N.J. 1980) (approves modern supplemental deadlock charges)
  • Allen v. United States, 164 U.S. 492 (U.S. 1896) (relevance of juror deliberation instructions)
  • State v. Yough, 208 N.J. 397 (N.J. 2011) (mistrial and coercion concerns in jury deliberations)
Read the full case

Case Details

Case Name: State of New Jersey v. Wedpens Dorsainvil
Court Name: New Jersey Superior Court Appellate Division
Date Published: May 2, 2014
Citation: 435 N.J. Super. 449
Docket Number: A-0879-10
Court Abbreviation: N.J. Super. Ct. App. Div.