State v. Ivonne Saavedra (073793)
117 A.3d 1169
| N.J. | 2015Background
- Defendant Ivonne Saavedra, a Board of Education employee, allegedly removed hundreds of confidential student records from Board files.
- Those records included originals and copies protected by FERPA and state privacy laws; Board reported alleged theft to authorities.
- Grand jury indicted Saavedra on official misconduct and theft by unlawful taking of public documents.
- Saavedra moved to dismiss, arguing Quinlan immunized her conduct and that evidence was withheld; trial court denied.
- Appellate Division affirmed, holding the State presented a prima facie case and did not withhold exculpatory evidence.
- This Court affirms, clarifying Quinlan does not govern criminal prosecutions and that a potential justify/claim of right defense may be raised at trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether indictment should be dismissed for lack of prima facie evidence | Saavedra | Saavedra | Indictment supported by prima facie evidence on both counts |
| Whether Quinlan applies to criminal prosecutions to immunize conduct | Saavedra | State | Quinlan does not govern criminal prosecutions; no error in upholding indictment |
| Whether the State violated Hogan by withholding exculpatory evidence | Saavedra | State | State did not withhold clearly exculpatory evidence as to guilt or justify defense |
| Whether due process or vagueness challenges warrant dismissal on public policy | Saavedra | State | Statutes not void for due process vagueness; public policy against discrimination does not require dismissal |
| Whether a claim-of-right/justification defense should be available at trial | Saavedra | State | Affirmative defense may be available; remand for trial to determine applicability with full record |
Key Cases Cited
- State v. Hogan, 144 N.J. 216 (1996) (prosecutor's duty to present exculpatory evidence; grand jury proceedings)
- State v. Morrison, 188 N.J. 2 (2006) (grand jury standard for dismissal; abuse of discretion standard)
- In re Loigman, 183 N.J. 133 (2005) (grand jury independence and rights to question witnesses)
- Quinlan v. Curtiss-Wright Corp., 204 N.J. 239 (2010) (LAD retaliation balancing test; not controlling in criminal prosecutions)
- State v. Perez, 185 N.J. 204 (2005) (broad definition of public servant; official misconduct elements)
- Mejia v. State, 141 N.J. 475 (1995) (claim of right defense to theft under N.J.S.A. 2C:20-2(c))