State v. Calleia
206 N.J. 274
| N.J. | 2011Background
- Calleia was convicted by a Monmouth County jury of first-degree murder, tampering with evidence, and hindering apprehension, and sentenced to 50 years with NERA parole ineligibility.
- State appealed the admissibility of the victim Susan Calleia's state-of-mind hearsay statements offered to establish motive.
- Susan Calleia disappeared on Oct. 20, 2005; her body was found in the cargo area of the family Lexus SUV at the PNC Arts Center, allegedly indicating possible sexual assault and violent death by manual strangulation.
- The State's theory hinged on Susan's statements about wanting a divorce and defendant's awareness of those plans; trial evidence included multiple friends' testimony and defendant's statements to police.
- The Appellate Division reversed, finding the decedent's state-of-mind statements improper to prove motive under Machado and related cases.
- The Supreme Court held that such hearsay statements can be admissible to prove motive if the declarant's facts would have given rise to motive to the defendant, reversed the Appellate Division, and reinstated Calleia's conviction, with remand for sentencing issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May a deceased victim's state-of-mind statements prove the defendant's motive? | Calleia; State argues statements admissible to show relationship and motive. | Calleia; State's approach misuses state-of-mind hearsay to infer motive. | Not per se inadmissible; may be admissible if probative of motive and balanced under 403. |
| Are such statements harmless error given other evidence? | State contends overwhelming evidence renders any error harmless. | Appellate error could have biased the jury despite other evidence. | Harmless; cumulative nature and lack of fear content reduce prejudice; conviction reinstated. |
| What is the proper scope for admitting motive evidence via state-of-mind statements? | State argues broad leeway to admit related to defendant's knowledge of victim's conduct. | Machado/precedents caution against broad use; require knowledge by defendant. | A victim's state-of-mind statements may provide motive evidence if the defendant likely knew the facts and 403 balancing is satisfied. |
Key Cases Cited
- State v. Baldwin, 47 N.J. 379 (1966) (admissible to show motive where victim intended to testify against defendant)
- State v. Machado, 111 N.J. 481 (1988) (state-of-mind statements should not prove defendant's motive or conduct unless tailored)
- Downey, 206 N.J. Super. 382 (App.Div. 1986) (victim's fear statements generally inappropriate unless tied to defendant's knowledge)
- Prudden, 212 N.J. Super. 608 (App.Div. 1986) (fear-based statements treated cautiously for motive evidence)
- Benedetto, 120 N.J. 250 (1990) (victim's fear-alone statements not admissible; probative value minimal)
- Dreher, 251 N.J. Super. 300 (App.Div. 1991) (admissions about divorce used to prove motive; controversy over admissibility)
- State v. Rogers, 19 N.J. 218 (1955) (motive may be proved by various evidentiary means)
- State v. Covell, 157 N.J. 554 (1999) (reaffirmed broad admissibility of motive evidence when material)
- Castagna, 400 N.J. Super. 164 (App.Div. 2008) (admissible related to motive in domestic context)
- State v. Rose, 206 N.J. 141 (2011) (motive evidence admissible; prior acts may show motive)