STATE OF NEW JERSEY VS. MICHAEL WASHINGTON (16-08-0636, 17-10-0572, and 18-01-0045, SOMERSET COUNTY AND STATEWIDE), A-2537-18

In October 2017 William Roberts was shot on Church Street and later died; witness descriptions and surveillance imagery showed a shooter wearing gray clothing.
Police recovered gray clothing from a nearby house two weeks later; two jailhouse informants testified that defendant admitted shooting Roberts and described wearing gray.
Defendant gave a sworn statement implicating a man called “Junior,” then testified at trial repudating that statement and claiming he shot Roberts in self‑defense.
A jury convicted defendant of aggravated manslaughter (lesser‑included of murder) and two weapons offenses; he later pled guilty to unrelated gun and drug charges that produced consecutive and concurrent terms.
The trial judge imposed an aggregate 27‑year sentence with significant parole ineligibility but merged one weapon count; defendant appealed, challenging (1) self‑defense jury instructions, (2) lack of tailored recklessness guidance for aggravated manslaughter, and (3) imposition of consecutive sentences without a Yarbough analysis.
The Appellate Division affirmed the convictions but vacated the consecutive sentencing portion and remanded for resentencing because the judge did not articulate Yarbough factors or explain the overall fairness of consecutive terms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury should have been specifically told to acquit on the manslaughter counts if self‑defense was not disproven beyond a reasonable doubt	State: the court's instruction (followed model charge and applied to all homicide forms) was adequate	Washington: judge should have expressly told jurors they must acquit aggravated/reckless manslaughter if self‑defense acquits murder	Held: No plain error; charge tracked the model, stated self‑defense applies to all homicide counts and that reasonable doubt requires acquittal
Whether the judge erred by not tailoring the recklessness evidence summary to aggravated manslaughter	State: no request was made to tailor and omission did not make instruction misleading	Washington: judge should have summarized evidence relevant to recklessness for the lesser offense	Held: No abuse of discretion or plain error; tailoring is discretionary and unnecessary here given clarity of law and strong State proof
Whether consecutive sentences must be vacated for lack of Yarbough analysis	State: consecutive terms were justified by separate offenses and statutory provisions but judge need not repeat every factor on record	Washington: judge failed to articulate Yarbough factors or reasons for overall fairness of consecutive terms	Held: Vacated in part and remanded for resentencing because the judge cited Yarbough but did not analyze or place specific reasons on the record as required

State v. Yarbough, 100 N.J. 627 (N.J. 1985) (establishes factors and requirement to articulate reasons for imposing consecutive sentences)
State v. Torres, 246 N.J. 246 (N.J. 2021) (requires explicit explanation of overall fairness as part of Yarbough analysis)
State v. Miller, 108 N.J. 112 (N.J. 1987) (emphasizes placing reasons for consecutive sentences on the record)
State v. Randolph, 210 N.J. 330 (N.J. 2012) (remand required where court fails to give proper reasons for consecutive sentences)
State v. Galicia, 210 N.J. 364 (N.J. 2012) (defines self‑defense justifications and standards)
State v. O'Neil, 219 N.J. 598 (N.J. 2014) (self‑defense defense applies to all forms of homicide, including aggravated manslaughter)
State v. Rodriguez, 195 N.J. 165 (N.J. 2008) (addresses application of self‑defense to lesser homicide offenses)
State v. Green, 86 N.J. 281 (N.J. 1981) (stresses importance of accurate jury instructions as the jury’s roadmap)