State v. Campfield, 213 N.J. 218

Defendant Kevin Campfield fatally drowned Ivory Bennett after a confrontation on January 17, 2006.
Campfield admitted, after drinking, to punching Bennett, robbing him, and forcing him to remove most of his clothing on a cold night.
Bennett’s death occurred after being chased into woods where he died from drowning; bodily injuries included blunt head trauma.
Campfield pled guilty to second-degree reckless manslaughter and second-degree robbery under a plea agreement, with eight and seven year sentences consecutive and subject to NERA.
Appellate Division vacated the reckless manslaughter conviction for an inadequate factual basis; the Court granted certification.
Supreme Court reinstated the conviction, holding the plea had an adequate factual basis under Rule 3:9-2, and remanded for Barboza-style restoration of charges if remand occurs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the plea colloquy provided an adequate factual basis for reckless manslaughter.	State argues admissions showed reckless disregard and causation.	Campfield contends the colloquy failed to prove awareness of risk of death.	Yes; the colloquy established a sufficient factual basis.
Whether causation and mens rea were proven for recklessness under N.J.S.A. 2C:11-4(b).	State contends risk was consciously disregarded; death within scope of risk.	Defendant argues lack of explicit admission to risk of death.	Adequate proof of recklessness and causation found.
What is the proper remedy if a plea lacks a sufficient factual basis on appeal.	State urges reinstate all counts and restore pre-plea positions.	Remedy should follow Barboza, vacating only the deficient plea.	Remand with Barboza-style restoration appropriate; majority’s full reinstatement of charges согласен with Barboza.

State ex rel. T.M., 166 N.J. 319 (2001) (factual basis must exist for plea; record aids appellate review)
State v. Sainz, 107 N.J. 283 (1987) (elements must be addressed in plea colloquy)
State v. Smullen, 118 N.J. 408 (1990) (admissible basis must come from defendant's admissions)
State v. Barboza, 115 N.J. 415 (1989) (remedy when plea lacks adequate factual basis: vacate and restore positions)
State v. Williams, 190 N.J. 114 (2007) (recklessness requires conscious disregard of substantial unjustified risk)
State v. Pelham, 176 N.J. 448 (2003) (jury must examine causal relationship and intervening causes)
State v. Jenkins, 178 N.J. 347 (2004) (recklessness may involve risk of death even if not certain)
State v. Lightner, 99 N.J. 313 (1985) (remedy and approach when plea lacks adequate factual basis)