State v. Gillispie, 208 N.J. 59

Barnegat double homicide on the night of November 28, 2000, led to investigations of Buttler and Gillispie as suspects.
Twenty days earlier, a Bronx barbershop robbery with a gun used by the same shooters was admitted as other-crimes evidence to link the defendants to the Barnegat murders.
The trial court admitted the Bronx evidence under Cofield's four-prong test, finding strong probative value on identity and acceptable prejudice.
Appellate Division reversed the convictions for both defendants due to unduly prejudicial, unsanitized details of the Bronx shooting, deeming the error not harmless.
The Supreme Court granted certification to review the State’s obligation to sanitize other-crimes evidence under N.J.R.E. 404(b) and Cofield.
The Court reverses the Appellate Division, remanding for consideration of remaining issues; it approves admission of the gun-link to identity but rejects the detailed Bronx-robbery evidence as unduly prejudicial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 404(b) evidence was admissible under Cofield	State: probative on identity outweighs prejudice	Gillispie/Buttler: prejudicial; details should be sanitized	Admissible for identity; details of Bronx shooting must be sanitized
Was the fourth Cofield prong satisfied given prejudicial details	Evidence's probative value outweighed prejudice	Details were unduly prejudicial and not outweighed	Admitting detailed Bronx-barbershop evidence violated Cofield's fourth prong
Did the trial court adequately sanitize the 404(b) evidence for jury	Sanitization unnecessary if probative value strong	Sanitization required to avoid prejudice	Court held sanitization was required; failure was reversible error
Whether the error was harmless given overwhelming evidence	Overwhelming evidence supports conviction even without sanitized details	Undisclosed prejudice could have altered verdict	Harmless error analysis favored reversal; yet Court remands to address issues, not an outright affirmance
Whether restriction on Mercer's plea credibility instruction was needed	Credibility guided by plea; no error if adequately challenged	Needed explicit instruction; failure prejudicial	Adams governs; no basis to reverse on pre-Adams trials; retrial instructions discussed

State v. Cofield, 127 N.J. 328 (1992) (established four-prong Cofield test for 404(b) admissibility)
State v. Darby, 174 N.J. 509 (2002) (cautionary balancing and sanitization of other-crimes evidence)
State v. Barden, 195 N.J. 375 (2008) (deference to trial court on 404(b) decisions; limits on prejudice)
State v. Fortin, 162 N.J. 517 (2000) (signature-crime framework for identity; discusses 404(b) context)
State v. Adams, 194 N.J. 186 (2008) (plea-credibility instruction limits; governs at retrial)
State v. Rose, 206 N.J. 141 (2011) (limits and instructions regarding 404(b) evidence; balancing)
State v. Hardaway, 269 N.J. Super. 627 (App. Div. 1994) (sanitization and prejudicial impact of 404(b) evidence)