STATE OF NEW JERSEY VS. JULIAN SANDERSÂ (W-2017-7415-0714, ESSEX COUNTY AND STATEWIDE) (RECORD IMPOUNDED), A-4350-16T6

Background

Defendant Julian Sanders was charged with murder and related weapons offenses after surveillance video and a witness placed him at the scene where Kendal Anthony was stabbed and died.
Pretrial Services produced a Public Safety Assessment (PSA) showing prior indictable and disorderly-person convictions and recommended no release; prosecutor moved for pretrial detention under the Criminal Justice Reform Act (CJRA).
Defendant conceded probable cause and applicability of the statutory presumption of detention for murder but argued he acted in self-defense, had community and family ties, nonviolent criminal history, and would accept supervised release.
The trial court reviewed the surveillance video (no audio), found defensible inferences of self-defense, concluded the State’s murder case was not strong, and determined defendant rebutted the presumption by a preponderance.
The court ordered release on 24-hour home supervision and electronic monitoring; the State appealed the release order.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendant rebutted the statutory presumption of pretrial detention for murder (N.J.S.A. 2A:162-19(b)).	PSA no-release recommendation, surveillance video and ID supported strong evidence of murder; presumption plus recommendation should weigh heavily for detention.	Defendant argued the video showed he was not the aggressor and raised a viable self-defense claim; family ties and nonviolent history support supervised release.	Court did not abuse discretion: defendant rebutted the presumption by preponderance based on video and other factors; release with conditions ordered.
Whether the court may consider evidence of an affirmative defense (self-defense) at a detention hearing and draw inferences from the video.	State: detention hearings should not become mini-trials; prosecution need not disprove every defense at this stage.	Defendant: self-defense evidence is relevant to danger and weight-of-evidence factors under CJRA.	Court properly considered self-defense-related inferences from the video when assessing danger and weight of evidence.
Proper weight of Pretrial Services’ no-release recommendation and its interaction with the statutory presumption.	State: a no-release recommendation is prima facie evidence and should make overcoming the presumption more difficult.	Defendant: the recommendation and presumption are both offense-based and should not be compounded; defendant may rebut by preponderance.	Recommendation cannot increase the defendant’s burden beyond the legislated preponderance standard; court should not treat it as amplifying the presumption.
Standard of review on appeal of a detention decision based on video evidence.	State urged a more deferential or State-favoring view given charged offense gravity.	Defendant relied on S.S. and CJRA’s liberal construction protecting liberty; trial court's inferences from video entitled to deference.	Appellate review is for abuse of discretion; where permissible inferences from video are reasonable, trial court findings stand. The court’s decision was affirmed.

Key Cases Cited

State v. S.S., 229 N.J. 360 (N.J. 2017) (trial-court inferences from video evidence entitled to deference unless clearly mistaken)
State v. C.W., 449 N.J. Super. 231 (App. Div. 2017) (abuse-of-discretion standard and CJRA context for pretrial detention decisions)
State v. Robinson, 229 N.J. 44 (N.J. 2017) (CJRA liberal construction and distinction between indictment/detention standards)
State v. Steele, 430 N.J. Super. 24 (App. Div. 2013) (abuse-of-discretion review when trial court considers relevant factors)
United States v. Salerno, 481 U.S. 739 (U.S. 1987) (principle that pretrial detention is a narrowly limited exception to liberty)