STATE OF NEW JERSEY VS. EUGENE C. TAYLOR (15-10-1164, BURLINGTON COUNTY AND STATEWIDE)(RECORD IMPOUNDED), A-1076-16T2

Background

Early morning encounter (May 14, 2013): police responded to reports of Taylor yelling about religion; Officer Ambrifi confronted him, used mace and a flashlight, and was then head-butted and wrestled with; Ambrifi fired four shots and was also shot in the leg during struggle for his gun. Taylor later hospitalized and diagnosed with schizophrenia.
Prior to indictment, a forensic psychologist evaluated Taylor and concluded he suffered paranoid schizophrenia at the time of the incident and could not distinguish right from wrong; hospital records from Ann Klein corroborated mental-health treatment.
The State presented the incident to a grand jury; the officer and acquaintances testified (including that Taylor had become preoccupied with religion/death beforehand). The defense mental-health report and hospital records were not presented to the grand jury.
Taylor moved to dismiss the superseding indictment, arguing the State had a duty to present clearly exculpatory evidence (his psychiatric report/hospital records) and to instruct the grand jury about diminished capacity/insanity; the trial court denied the motion and reconsideration.
Appellate division affirmed, holding the prosecutor had no obligation to present expert psychiatric opinion or give defensive legal instructions to the grand jury because the evidence was not "clearly exculpatory" and would require credibility determinations and a trial to resolve affirmative defenses.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Did the State have a duty to present psychiatric evidence to the grand jury?	No duty unless evidence is clearly exculpatory.	The State should have presented Dr. Hugonnet’s report and hospital records; they were clearly exculpatory.	No duty here; the psychiatric evidence was opinion-based and not clearly exculpatory because it required credibility assessment.
2. Must the prosecutor give grand jury legal instructions on diminished capacity/insanity?	Instructions only required when facts clearly establish the defense.	The grand jury should have been instructed on diminished capacity and insanity.	No instruction required; grand jury is accusatory, not adjudicatory, and instructions on affirmative defenses are for trial.
3. Would allowing the grand jury to consider insanity/diminished-capacity convert it into an adjudicatory body or conflict with commitment laws?	It could improperly convert the grand jury and conflict with statutory commitment procedures.	Taylor argued permitting consideration would not cause those problems and is appropriate.	Court agrees it would distort grand jury function and the statutory commitment scheme contemplates adjudication post-indictment.
4. Did the prosecutor have "actual knowledge" such that non-disclosure violated Hogan/Saavedra?	Prosecutor lacked obligation absent actual knowledge that evidence both directly negates guilt and is clearly exculpatory.	Taylor claimed prosecutor had the materials/knowledge and therefore a duty to present them.	Court found no obligation to present the materials as clearly exculpatory; even if known, the evidence required credibility resolution and was not compelled for grand jury presentation.

Key Cases Cited

State v. Hogan, 144 N.J. 216 (1996) (sets standard for when a prosecutor must present exculpatory evidence to the grand jury)
State v. Saavedra, 222 N.J. 39 (2015) (reviews grand jury nondisclosure under Hogan and requires "actual knowledge" for mandatory disclosure)
State v. Scherzer, 301 N.J. Super. 363 (App. Div. 1997) (opinion evidence that requires credibility determinations is not "clearly exculpatory" for grand jury purposes)
State v. Nataluk, 316 N.J. Super. 336 (App. Div. 1998) (diminished capacity is a failure-of-proof defense negating mens rea)
State v. Zola, 112 N.J. 384 (1988) (burden and proof standards for mental-condition defenses)
State v. Galloway, 133 N.J. 631 (1993) (rage/loss of control that does not impair cognitive capacity does not establish diminished capacity)
State v. Breakiron, 108 N.J. 591 (1987) (insanity is an affirmative defense permitting a not-guilty-by-reason-of-insanity verdict)
State v. Krol, 68 N.J. 236 (1975) (procedures and constitutional limits on commitment following insanity adjudication)