State of New Jersey v. Habeeb Robinson, 154 A.3d 187

Habeeb Robinson was arrested for murder; the probable cause affidavit and PLEIR alleged two eyewitness identifications and surveillance video identifying him as the shooter.
Prosecutor filed for pretrial detention under New Jersey's Bail Reform Act; defense sought discovery of underlying materials (eyewitness statements, photo array, surveillance video, initial police reports).
At the January 10, 2017 detention hearing the State produced only the probable cause affidavit and the PLEIR and refused broader discovery; judge ordered production of the witness statements, photo array, surveillance video, and initial police reports.
The State appealed the discovery order; the Appellate Division reviewed whether Rule 3:4-2(c)(1)(B) requires production of materials “relating to the pretrial detention application.”
The court construed the rule in light of the Bail Reform Act, the rulemaking history (Criminal Practice Committee report and the Attorney General’s dissent), and principles of rule interpretation, and affirmed the trial court’s discovery order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of discovery under R. 3:4-2(c)(1)(B): what documents must the State produce when seeking pretrial detention?	State: obligation is limited to producing the probable cause affidavit and the PLEIR (and only to documents it explicitly "relies on").	Robinson: Rule requires production of all statements/reports in State’s possession that relate to the detention application (e.g., witness statements, photo array, surveillance video, initial reports).	The court held the State must produce all statements or reports in its possession that relate to the factual assertions supporting the detention application; affirmed production of eyewitness statements, photo array, surveillance video, and initial police reports.

State v. Womack, 145 N.J. 576 (Supreme Court of New Jersey) (possession rule: materials held by police are imputed to the prosecutor for discovery)
State v. Mustaro, 411 N.J. Super. 91 (App. Div. 2009) (prosecutor’s discovery duty extends to materials in law enforcement possession)
In re N.H., 226 N.J. 242 (Supreme Court of New Jersey) (juvenile waiver hearings require full discovery to ensure meaningful opportunity to be heard; protective orders available)
Wiese v. Dedhia, 188 N.J. 587 (Supreme Court of New Jersey) (court-rules interpretation follows statutory-construction canons)
Shelton v. Restaurant.com, 214 N.J. 419 (Supreme Court of New Jersey) (presumption that every word in a rule has meaning)