State v. Buckley
216 N.J. 249
| N.J. | 2013Background
- On Aug. 12, 2008, Buckley, a police lieutenant, drove a rental Dodge Viper with Zerby, another lieutenant, as passenger; Buckley’s driving is at issue in a vehicular homicide prosecution.
- Zerby died from blunt-force injuries; Buckley was indicted for second-degree vehicular homicide under N.J.S.A. 2C:11-5.
- State seeks to admit seat belt evidence and pole-placement evidence to prove causation under N.J.S.A. 2C:2-3(c) but the trial court allowed limited consideration and the Appellate Division affirmed.
- The trial court deterrmined the seat belt evidence could be considered as an intervening act under N.J.S.A. 2C:2-3(c) and that pole placement evidence might be relevant to causation.
- The Court ultimately holds that seat belt evidence is admissible only as context for causation under the first prong, with limiting instructions, and pole-placement evidence is inadmissible for causation; the matter is remanded.
- The opinion also discusses the statutory causation framework of N.J.S.A. 2C:2-3 and the appropriate scope of jury consideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of seat belt evidence for causation | State argues seat belt evidence is irrelevant to both but-for causation and first-prong causation | Buckley contends evidence is relevant to intervening causation | Seat belt evidence is admissible for background only with limiting instruction |
| Admissibility of pole-position evidence for causation | State argues pole position may show an intervening cause | Buckley contends it is not causally related to awareness under the first prong | Pole placement evidence is inadmissible for causation under N.J.S.A. 2C:2-3(c) first prong |
| Scope of juror consideration under N.J.S.A. 2C:2-3(c) | State relies on first prong to show awareness of risk | Buckley argues second prong not applicable here | Court confines analysis to first prong; second prong not considered since not relied upon |
Key Cases Cited
- State v. Pelham, 176 N.J. 448 (N.J. 2003) (intervening causation and two-prong test guidance)
- State v. Martin, 119 N.J. 2 (N.J. 1990) (causation and culpability framework in recklessness cases)
- State v. Jamerson, 153 N.J. 318 (N.J. 1998) (victim conduct and causation in fatality cases)
- State v. Eldridge, 388 N.J. Super. 485 (N.J. Super. 2006) (appellate review of causation evidence in vehicular homicide)
- State v. Buda, 195 N.J. 278 (N.J. 2008) (review of evidentiary rulings under limited appellate scrutiny)
- State v. Rose, 206 N.J. 141 (N.J. 2011) (limiting background evidence under factual causation)
- State v. Campfield, 213 N.J. 218 (N.J. 2013) (role of risk awareness in recklessness causation)
- State v. Shelley, 205 N.J. 320 (N.J. 2011) (statutory interpretation in causation context)