STATE OF NEW JERSEY v. CHRISTOPHER FIGUEROA (07-09-3171, A-2450-15T3

Background

In 2010 Christopher Figueroa pled guilty to first‑degree aggravated manslaughter for shooting two men on March 8, 2007; he admitted shooting both after a dispute and taking $20,000; sentence: 25 years with 85% parole ineligibility.
Post‑conviction, Figueroa alleged trial/plea counsel was ineffective for (a) not filing a suppression motion for his custodial interview, (b) failing to investigate/interview two witnesses (R.M., who initially implicated him then recanted; and C.O., an alleged alibi), (c) advising there was no alternative to pleading guilty, and (d) having a conflict of interest. He also moved to withdraw his guilty plea.
Key prosecution evidence: R.M.’s initial statement describing defendant’s admissions, corroborated by blood matching a victim found in her home and a $1,000 bank deposit; a video‑recorded custodial interview in Brockton in which defendant acknowledged Miranda warnings and spoke with investigators; co‑defendant’s guilty plea implicating Figueroa.
R.M.’s later handwritten recantation (unsigned) and C.O.’s later 2015 statement (contradicting her earlier 2007 statement and not sworn) were offered by defendant as new/exculpatory material.
The PCR court denied relief without an evidentiary hearing, finding (inter alia) the Miranda waiver was knowing/voluntary, the interview not coercive, R.M.’s recantation unpersuasive given corroboration, C.O.’s late unsworn statement unreliable, and no showing of counsel conflict or prejudice to satisfy Strickland.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for failing to file suppression motion for custodial statements	State: waiver was knowing and voluntary; motion would be meritless	Figueroa: interview was coercive/violated Fifth Amendment and counsel should have moved to suppress	Denied — waiver was valid, interview noncoercive; suppression motion would have been meritless; no deficient performance
Ineffective assistance for failing to investigate/interview R.M. (recantation)	State: R.M.’s original statement was corroborated by objective evidence	Figueroa: counsel should have evaluated recantation to undermine prosecution case	Denied — recantation had limited value given corroboration (blood, bank records); counsel not ineffective
Ineffective assistance for failing to investigate/interview C.O. (alibi)	State: C.O.’s original 2007 statement offered no exoneration; 2015 unsworn statement is unreliable	Figueroa: C.O.’s alibi would have shown he was elsewhere and avoided guilty plea	Denied — only an unsworn, contradictory late statement; no reliable affidavit; no prejudice shown
Motion to withdraw guilty plea due to counsel’s ineffective assistance/conflict	State: plea was favorable and counseled; defendant didn’t meet Strickland/DiFrisco burden to show he would have proceeded to trial	Figueroa: counsel’s failures and conflict coerced plea; would have gone to trial otherwise	Denied — no deficient performance or reasonable probability he would have rejected the favorable plea and insisted on trial

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (establishing two‑part ineffective assistance test)
State v. Fritz, 105 N.J. 42 (adopting Strickland in New Jersey)
State v. Nuñez‑Valdéz, 200 N.J. 129 (standard for prejudice when challenging a guilty plea)
State v. DiFrisco, 137 N.J. 434 (guilty plea withdrawal—prejudice inquiry)
State v. Slater, 198 N.J. 145 (factors for plea withdrawal motions)
State v. O'Neal, 190 N.J. 601 (not ineffective to file meritless motion)
State v. Fisher, 156 N.J. 494 (burden to show suppression claim meritorious)
State v. Cummings, 321 N.J. Super. 154 (affidavit requirement for ineffective‑investigation claims)
Miranda v. Arizona, 384 U.S. 436 (Miranda warnings and custodial interrogation standards)