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