STATE OF NEW JERSEY VS. DANIEL BEDFORD(13-03-0681, ESSEX COUNTY AND STATEWIDE), A-3518-14T4

Background

Early morning June 6, 2012: victim Kareem Montague was found dead in the back seat of his car; a large serrated knife with blood was recovered in the vehicle. Autopsy showed lethal penetration to the heart.
Defendant Daniel Bedford was identified by physical evidence in the car (wallet, ID, fingerprint) and surveillance showing him discarding a blood-stained sweatshirt.
Bedford admitted stabbing Montague but claimed self-defense, saying Montague produced a knife and lunged at him during a struggle; only eyewitness besides defendant was passenger Charlene Fields, whose account conflicted with Bedford's.
A jury convicted Bedford of first-degree carjacking, first-degree aggravated manslaughter (as a lesser-included of murder), unlawful possession of a knife, and possession of a knife for an unlawful purpose; some convictions were merged at sentencing.
The trial court sentenced Bedford to concurrent terms: 15 years (carjacking), 25 years (aggravated manslaughter), and 1 year (unlawful possession), with NERA parole ineligibility; VCCA assessments were largely imposed but two violent-crime assessments were miscalculated.
On appeal Bedford raised: (1) defective self-defense jury charge, (2) prejudicial credibility instruction regarding failure to contact police (defendant and aunt), and (3) excessiveness of the 25-year NERA sentence; review was for plain error where objections were not preserved.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether jury charge on self-defense improperly suggested defense applied to murder but not aggravated manslaughter	Charge, read as whole, adequately explained self-defense and its applicability to murder and lesser-included manslaughter offenses	Charge was defective and likely led jury to think self-defense applied to murder only, not aggravated manslaughter	Affirmed: charge read as whole made clear self-defense applied to murder and aggravated/reckless manslaughter; no plain error
Whether instruction permitting impeachment based on failure to contact police unfairly tipped credibility against defendant	Court properly allowed impeachment; limiting instruction confined use to credibility assessment	Instruction improperly linked defendant's and aunt's failures to contact police and prejudiced credibility	Affirmed: instruction addressed credibility, not constitutional silence, and could not have produced an unjust result
Whether 25-year aggravated manslaughter NERA sentence was manifestly excessive	Sentence within statutory range for first-degree aggravated manslaughter/carejacking and supported by aggravating factors the judge identified	Sentence excessive; trial court failed to adequately state reasons/mitigating factors as required for appellate review	Remanded for resentencing: judge must provide clearer Fuentes-compliant statement of reasons for quantitative/qualitative weight of factors
Whether VCCA assessments were correctly imposed	State imposed assessments generally; court imposed $50 VCCA assessments for two violent crimes	Assessments for aggravated manslaughter and carjacking should be $100 each under statute	Remand to correct VCCA assessments (two $50 charges should be $100 each)

Key Cases Cited

State v. Rodriguez, 195 N.J. 165 (N.J. 2008) (self-defense is a defense to murder and lesser-included manslaughter)
State v. Gentry, 439 N.J. Super. 57 (App. Div. 2015) (reversal where jury was told self-defense applied to murder but not to aggravated manslaughter)
State v. Singleton, 211 N.J. 157 (N.J. 2012) (jury charges must comprehensibly explain applicable law)
State v. Camacho, 218 N.J. 533 (N.J. 2014) (plain-error standard and prejudice analysis for jury instructions)
State v. Adams, 194 N.J. 186 (N.J. 2008) (definition and application of plain-error standard)
State v. Jordan, 147 N.J. 409 (N.J. 1997) (plain-error standard discussion)
State v. Fuentes, 217 N.J. 57 (N.J. 2014) (sentencing courts must give careful, detailed statement of reasons to allow appellate review)
State v. Bieniek, 200 N.J. 601 (N.J. 2010) (importance of sentencing court's statement of reasons)
State v. Roth, 95 N.J. 334 (N.J. 1984) (framework for sentencing review and need to base findings on competent credible evidence)
State v. Brown, 190 N.J. 144 (N.J. 2007) (permissible impeachment by failure to report to police when objective circumstances make reporting reasonable)
State v. Muhammad, 182 N.J. 551 (N.J. 2005) (distinguishing impeachment from Fifth Amendment/privilege concerns)