STATE OF NEW JERSEY v. YOON S. CHOI (17-05-0264, MERCER COUNTY AND STATEWIDE)
A-5638-18
| N.J. Super. Ct. App. Div. | Mar 25, 2022Background
- On December 9, 2014, defendant Yoon Choi stabbed his former girlfriend, Myung Jeon, in a Subway restaurant during an argument; the assault was captured on surveillance and witnessed by bystanders.
- Jeon suffered catastrophic cervical spinal cord injuries, was hospitalized, and died on July 6, 2016 from complications related to the stab wounds.
- Police interviewed Choi at the station; he had limited English but signed a Miranda waiver after detectives read the warnings aloud; he then gave a confession describing the dispute and stabbing.
- Choi moved to suppress his statements; the trial court denied suppression, finding his Miranda waiver knowing, intelligent, and voluntary.
- A jury convicted Choi of first-degree murder and weapon offenses; the court sentenced him to 45 years with 38.25 years of parole ineligibility under the No Early Release Act.
- On appeal Choi challenged (1) denial of suppression, (2) failure to instruct passion/provocation manslaughter, (3) scope of treating physicians’ testimony, and (4) excessiveness of sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Validity of Miranda waiver/suppression | State: waiver was knowing, intelligent, voluntary; Choi responded appropriately and waived rights on the record | Choi: limited English meant waiver was not knowing or voluntary; suppression should have been granted | Court: affirmed denial; trial court’s factual findings supported waiver beyond a reasonable doubt |
| 2. Failure to instruct passion/provocation manslaughter | State: evidence did not support passion/provocation; words alone insufficient | Choi: jury should have been instructed on passion/provocation as lesser-included offense | Court: no plain error; record did not support an adequate provocation instruction |
| 3. Admissibility/scope of treating physicians’ testimony | State: treating doctors testified to diagnosis, treatment, prognosis permissible under N.J.R.E. 701 | Choi: testimony exceeded lay-opinion scope and was improper expert testimony | Court: no plain error; testimony limited to diagnosis/treatment and within treating-physician scope |
| 4. Excessive sentence | State: sentence within statutory range and supported by findings (risk of reoffense, deterrence) | Choi: 45-year term with lengthy parole bar is excessive | Court: affirmed; sentencing court acted within discretion and relied on competent, credible evidence |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings and waiver standard)
- State v. Presha, 163 N.J. 304 (2000) (prosecutor must prove waiver knowing, intelligent, voluntary beyond a reasonable doubt)
- State v. Nyhammer, 197 N.J. 383 (2009) (totality-of-circumstances test for voluntariness)
- State v. Denofa, 187 N.J. 24 (2006) (lesser-included offense instruction principles)
- State v. Galicia, 210 N.J. 364 (2012) (elements and limits of passion/provocation manslaughter)
- State v. Mauricio, 117 N.J. 402 (1990) (elements of passion/provocation)
- Delvecchio v. Twp. of Bridgewater, 224 N.J. 559 (2016) (treating physicians may testify as lay witnesses regarding diagnosis/treatment)
- Stigliano v. Connaught Lab'y, Inc., 140 N.J. 305 (1995) (scope of treating physician testimony)
- State v. Miller, 237 N.J. 15 (2019) (standard of appellate review for sentencing)
- State v. Coles, 218 N.J. 322 (2014) (deference to trial court factfindings on suppression)
