STATE OF NEW JERSEY VS. TIANLE LI (11-05-0690, MIDDLESEX COUNTY AND STATEWIDE), A-1834-19

Defendant Tianle Li was convicted of first-degree murder and third-degree hindering for poisoning her husband, Xiaoye Wang, with thallium; conviction affirmed on direct appeal.
State's evidence: acrimonious divorce and prior poisoning threats, defendant's access to and orders for thallium at her employer, returned thallium bottles with reduced content, thallium articles on her laptop, one‑way flight bookings to China, and an admission to a cellmate.
Trial court granted the State's in limine motion precluding an intervening-medical-malpractice defense regarding hospital care after Wang’s admission.
On PCR, Li argued trial counsel was ineffective for (1) failing to produce a medical expert on intervening cause, (2) failing to adequately advise her about testifying, and (3) committing cumulative errors; she sought an evidentiary hearing.
PCR judge (Toto) denied relief without a hearing, finding claims procedurally barred or failing the Strickland–Fritz two‑part ineffective assistance test; the Appellate Division affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Li)	Held
1. Was denial of PCR relief erroneous?	Denial proper: claims barred or meritless; no hearing required.	PCR relief warranted; factual disputes need hearing.	Affirmed denial; record disposes of claims; no hearing required.
2. Was counsel ineffective for not presenting a medical expert on intervening cause?	Intervening cause was previously rejected on direct appeal; expert would not change outcome.	An expert would have shown hospital malpractice caused death, breaking causal chain.	Barred by direct appeal; even on merits no intervening cause — Strickland not met.
3. Was counsel ineffective re: advice about defendant testifying?	Counsel informed Li; she waived knowingly; record supports this.	Counsel failed to properly advise, so she chose not to testify.	No prima facie claim; record shows informed, voluntary decision — Strickland not met.
4. Do cumulative errors require relief?	Alleged cumulative errors are either barred, speculative, or nonprejudicial.	Multiple counsel errors together deprived fair trial.	Meritless; defendant failed to identify admissible evidence or show prejudice.

Strickland v. Washington, 466 U.S. 668 (1984) (two‑part ineffective assistance standard)
State v. Fritz, 105 N.J. 42 (1987) (NJ adoption of Strickland standard)
State v. Blake, 444 N.J. Super. 285 (App. Div. 2016) (standard for de novo review where no evidentiary hearing held)
State v. McQuaid, 147 N.J. 464 (1997) (PCR cannot relitigate claims decided on the merits)
State v. Pelham, 176 N.J. 448 (2003) (intervening cause and causal‑chain principles)
State v. Marshall, 148 N.J. 89 (1997) (limits on using evidentiary hearings to explore PCR claims)
State v. Porter, 216 N.J. 343 (2013) (requirement to plead specific facts supporting PCR claims)
State v. Cummings, 321 N.J. Super. 154 (App. Div. 1999) (bald assertions insufficient to establish ineffective assistance)