State v. JAC
210 N.J. 281
| N.J. | 2012Background
- State's rape shield law, N.J.S.A. 2C:14-7, protects victim CA's privacy and limits evidence of her sexual conduct.
- CA, born 1991, alleged defendant J.A.C. sexually abused her when she was nine; crime occurred during a family arrangement period.
- In 2003 CA, then 12, engaged in explicit instant messages with adult men; discovery triggered family upheaval and potential relocation of CA.
- Defendant sought to admit content of CA's online messages to support a fabrication defense but was barred from introducing the messages' substantive content.
- Trial convicted defendant of first-degree aggravated sexual assault and other offenses; Appellate Division affirmed; Supreme Court granted review limited to the messages' content.
- Court held the instant messages constitute 'sexual conduct' under 2C:14-7(f) and applied Budis/Garron balancing to uphold exclusion of the message content to protect victims and avoid prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do CA's instant messages qualify as sexual conduct under 2C:14-7(f)? | State contends messages are sexual conduct and protected by the statute. | J.A.C. argues the content is relevant to fabrication and should be admitted. | Yes; messages constitute sexual conduct and are protected |
| Was the exclusion of the message content proper under Budis and Garron balancing? | Exclusion preserves victim privacy and avoids prejudice while allowing fabrication defense in other forms. | Exclusion deprives defense of critical context for fabrication claim. | Exclusion upheld; probative value outweighed by prejudice |
| Did the trial court adequately protect the defendant's fabrication defense within 2C:14-7's framework? | Court carefully applied 2C:14-7 and allowed non-content evidence relevant to fabrication. | Limiting the content prevented full exploration of motive to lie. | Yes; court ensured fabrication defense while safeguarding victim |
Key Cases Cited
- State v. Budis, 125 N.J. 519 (1991) (two-pronged test balancing relevance/necessity with prejudice and privacy)
- State v. Garron, 177 N.J. 147 (2003) (evidence relevant and necessary to defense must be admitted; consent issue)
- State v. Schnabel, 196 N.J. 116 (2008) (rape shield focus on protecting victim privacy while ensuring fair trial)
- State v. P.S., 202 N.J. 232 (2010) (protects privacy and limits unwarranted foraging for victim's prior conduct)