State v. Green, 197 A.3d 1136

In 2014 Carlos B. Green struck and killed a pedestrian; his BAC was 0.210% at the time of the accident.
Green had two prior DWI convictions (1998 and 2009) and attended mandatory IDRC educational courses after those convictions.
The State indicted Green for first‑degree vehicular homicide while intoxicated and sought to admit the prior DWI convictions and IDRC participation as Rule 404(b) other‑crimes evidence to prove recklessness (knowledge and conscious disregard of risk).
The trial court excluded the prior convictions under the Cofield four‑part test, finding undue prejudice and that the toxicology report provided less inflammatory evidence of recklessness.
The Appellate Division affirmed; the Supreme Court granted leave, heard argument (with the Attorney General as amicus), and affirmed, holding the priors inadmissible in this case while declining a per se rule.

Issue	State's Argument	Green's Argument	Held
Admissibility of prior DWI convictions under N.J.R.E. 404(b) to prove recklessness	Priors and IDRC attendance show knowledge of risks and are probative of recklessness; limiting instructions can cure prejudice	Priors are remote, unduly prejudicial, and cumulative given BAC evidence; no evidence of reckless driving apart from intoxication	Excluded: under Cofield balancing, prejudice (propensity inference, jury confusion on causation) outweighed probative value in these circumstances
Must courts apply the Cofield four‑part test or adopt a different standard	Invite NJ to follow other jurisdictions and relax Cofield’s fourth‑prong scrutiny	Cofield must be applied case‑by‑case; Bakka does not compel admission here	Cofield applies; trial courts must perform full analysis; no change to NJ precedent
Whether prior DWI convictions should be per se admissible in vehicular‑homicide prosecutions	Priors can be highly probative and other jurisdictions admit them; sometimes necessary to prove heightened awareness	Reject adoption of less protective rules; risk of unfair propensity inference	No per se rule: priors may be admissible in rare, fact‑specific circumstances (e.g., recent, highly similar conduct) but are not automatically admissible

State v. Cofield, 127 N.J. 328 (establishes the four‑part test for other‑crimes evidence)
State v. Bakka, 176 N.J. 533 (prior revocation may be probative of recklessness when the proscribed conduct is repeated)
State v. Rose, 206 N.J. 141 (discusses Cofield application and Rule 404(b) balancing)
State v. Reddish, 181 N.J. 553 (other‑crimes evidence requires rigorous scrutiny; appellate plenary review when Cofield not applied)
State v. Garrison, 228 N.J. 182 (noting the rigorous test for admitting other‑crimes evidence)
State v. Barden, 195 N.J. 375 (probative value vs. prejudice under other‑crimes analysis)
State v. Williams, 190 N.J. 114 (limits on applicability of Cofield’s similarity/temporal prong)
State v. Brunson, 132 N.J. 377 (sanitizing prior conviction evidence to reduce prejudice)
State v. Stanton, 176 N.J. 75 (intoxication alone may give rise to an inference of recklessness)