STATE OF NEW JERSEY VS. ERIC JAMESSTATE OF NEW JERSEY VS. REGINALD FELTONÂ (09-10-0966, UNION COUNTY AND STATEWIDE)(CONSOLIDATED), A-5561-14T2/A-2449-15T2

Background

Defendants Eric James and Reginald Felton were tried together for beating a victim with a wooden furniture leg; police chased suspects, found Felton in a bedroom and James in an attic, and a bloody table leg with the victim’s blood was recovered and DNA-matched. Two officers identified the defendants in court.
A jury convicted both of two counts of aggravated assault, unlawful possession of a weapon, and possession of a weapon for an unlawful purpose; Felton was also convicted of obstruction. Appellate affirmances and Supreme Court denial of certification followed.
Both defendants filed post-conviction relief (PCR) petitions asserting ineffective assistance of trial counsel (IAC): failures to investigate, to move for a Wade hearing on identifications, to conduct forensic testing, to adequately cross-examine the victim, and to object at trial or sentencing.
Judges Peim (James) and Daniel (Felton) denied the PCR petitions without evidentiary hearings after reviewing the trial record and applying the Strickland/Fritz standard, finding no prima facie IAC showing.
The Appellate Division consolidated the appeals and affirmed, holding defendants failed to allege specific facts showing deficient performance and a reasonable probability of a different outcome given the strength of the State’s case.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel rendered ineffective assistance by failing to investigate victim’s pre-assault whereabouts and interview potential witnesses	State: trial record and convictions valid; no prima facie IAC shown	James: counsel failed to investigate victim/girlfriend, which might undermine identification and credibility	Denied: allegations unsupported by record; even if true, would not likely change outcome
Whether counsel should have requested a Wade hearing or objected to identification evidence	State: identifications and procedure were proper; no showing of prejudice	Both: counsel failed to seek Wade hearing to challenge identification reliability	Denied: defendants did not show specific facts demonstrating deficient strategy or prejudice
Whether counsel failed to perform or seek forensic testing (clothing, weapon, car)	State: strength of DNA and eyewitness evidence obviates need; no prima facie showing	Felton: counsel failed to test items that might exculpate him (no blood/fingerprints)	Denied: claims lacked factual support and would not likely alter outcome given DNA and eyewitness evidence
Whether cumulative errors (failure to object, inadequate cross-examination, sentencing advocacy) require relief	State: isolated tactical choices; no reasonable probability of different verdict/sentence	Defendants: combined errors deprived them of effective counsel and a fair trial	Denied: tactical decisions entitled to deference; no reasonable probability undermining confidence in result

Key Cases Cited

United States v. Wade, 388 U.S. 218 (rejecting post-indictment lineup without counsel) (Wade addresses right to counsel at post-indictment identification procedures)
Strickland v. Washington, 466 U.S. 668 (1984) (establishing two-prong ineffective assistance standard)
State v. Fritz, 105 N.J. 42 (1987) (adopting Strickland standard in New Jersey)
State v. Hess, 207 N.J. 123 (2011) (deference to counsel decisions and avoiding hindsight review)
State v. Nash, 212 N.J. 518 (2013) (presumption of reasonable professional judgment by counsel)
State v. Pierre, 223 N.J. 560 (2015) (defining reasonable probability standard to undermine confidence in outcome)
State v. Porter, 216 N.J. 343 (2013) (prima facie PCR case requires specific facts/evidence)
State v. Jones, 219 N.J. 298 (2014) (bald assertions insufficient for IAC; must allege facts demonstrating substandard performance)
State v. Echols, 199 N.J. 344 (2009) (failure to object or move for mistrial does not automatically establish reversible error)