STATE OF NEW JERSEY VS. CHRISTOPHER M. JACKSONÂ (08-04-0523, MIDDLESEX COUNTY AND STATEWIDE), A-3605-15T1

Background

In 2008 Christopher M. Jackson was indicted for first‑degree murder, criminal restraint, and hindering apprehension; he pleaded guilty to first‑degree aggravated manslaughter in a negotiated plea dismissing other counts and with the State recommending up to 25 years subject to NERA.
At plea allocution Jackson admitted beating the victim after an altercation, binding him with a cord, stuffing a cloth in his mouth, hearing him gasp, and leaving without seeking aid; he affirmed the plea was voluntary.
Jackson later moved to withdraw the plea (denied), was sentenced to 23 years subject to NERA, and the sentence was affirmed on direct appeal (ESOA calendar) in 2011.
In 2013 Jackson filed a PCR petition claiming ineffective assistance of plea and sentencing counsel (failure to investigate/intoxication/diminished capacity/insanity/self‑defense, coercion into plea, and failure to press mitigating factors); the PCR court denied relief without an evidentiary hearing and denied reconsideration.
Jackson appealed; the Appellate Division reviewed the Strickland standard and the PCR‑hearing threshold and affirmed denial of PCR, finding the claims meritless or unsupported by specific facts and no prejudice shown.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jackson)	Held
Whether plea counsel was ineffective for failing to investigate/present mens rea defenses (voluntary intoxication, diminished capacity, insanity)	Counsel’s performance was adequate; aggravated manslaughter requires recklessness, not a mental state negated by voluntary intoxication, and record contained no evidence supporting incapacity or insanity	Counsel failed to investigate intoxication and mental‑health defenses and did not consult experts	Denied — counsel not ineffective; intoxication is not a defense to aggravated manslaughter and Jackson failed to show evidence of incapacity or insanity or prejudice under Strickland
Whether counsel was ineffective for failing to pursue self‑defense	Plea record showed use of deadly force was not reasonable — defendant separated from victim and beat him in response to taunts, so self‑defense was not viable	Counsel should have advanced self‑defense because victim made sexual advances	Denied — no reasonable basis for self‑defense; counsel not deficient
Whether plea was involuntary due to counsel coercion (threats of harsher sentence)	Plea was voluntary; Jackson affirmed understanding consequences at allocution and the potential sentence exposure (first‑degree murder) supported counsel’s advice	Counsel pressured/coerced Jackson to accept plea by threatening higher sentence if he refused	Denied — sworn allocution controls; counsel’s advice about sentencing exposure was appropriate and not coercive
Whether sentencing counsel was ineffective for failing to argue mitigating factors (hardship to dependents, cooperation)	Mitigating factors were not clearly supported by record (no custodial relationship with children, child support issues) and cooperation via confession does not clearly fit factor	Counsel should have argued factors (children hardship; cooperation/confession)	Denied — factors not clearly supported; no prejudice shown given 23‑year sentence within statutory range

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard) (establishes two‑prong test of performance and prejudice)
State v. Fritz, 105 N.J. 42 (adopts Strickland standard in New Jersey)
State v. Nuñez‑Valdéz, 200 N.J. 129 (ineffective assistance in guilty plea context; defendant must show would have insisted on trial)
State v. DiFrisco, 137 N.J. 434 (guilty plea ineffective assistance framework)
State v. Preciose, 129 N.J. 451 (prima facie PCR claim standard; evidentiary hearing required if prima facie shown)
State v. Jones, 219 N.J. 298 (view facts favorably to defendant when assessing prima facie PCR claims)
State v. Porter, 216 N.J. 343 (defendant must allege specific facts to support PCR claims)
State v. Cummings, 321 N.J. Super. 154 (bald assertions insufficient for PCR)
State v. Warren, 104 N.J. 571 (voluntary intoxication as defense generally)
State v. Junita, 224 N.J. Super. 711 (aggravated manslaughter elements and intoxication inapplicability)
State v. Urbina, 221 N.J. 509 (self‑defense requires honest and reasonable belief in necessity of deadly force)
State v. Bieniek, 200 N.J. 601 (courts obliged only to find mitigating factors clearly supported by record)
State v. Dalziel, 182 N.J. 494 (mitigating factor of hardship to dependents requires clear record support)
State v. Read, 397 N.J. Super. 598 (questioning whether confession constitutes cooperation under mitigating factor)