State v. Jarrett Parker (068966), 82 A.3d 926

Defendant Jarrett Parker allegedly carjacked a Honda with a two-year-old in the back seat, following a street confrontation and assault on the car’s occupants.
At trial, the State cross-examined Parker about aliases listed in judgments of conviction, arguing it affected credibility; defense sought to exclude alias references.
The trial judge permitted questioning about aliases because they appeared in certified judgments, allowing impeachment by facts within the four corners of the judgments.
During cross-examination and summation, the State framed Parker as someone who lies, using false names to impeach credibility and bolster its case.
Parker was convicted of first-degree carjacking and sentenced to twenty years with parole ineligibility under N.J.S.A. 2C:43-7.2, with related supervision.
The Appellate Division affirmed; the Supreme Court granted certification and reversed, remanding for a new trial due to improper use of alias evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether alias evidence on cross-exam sufficient for impeachment	Parker used aliases; judgments admissible to prove prior convictions	Aliases not subject of convictions; improper for impeachment under 405(a) and 608	Admissibility of alias evidence violated 405(a) and 608; reversal required
Effect of summation referencing aliases	Closing remarks properly attacked credibility using true facts	Summation improperly linked alias lies to credibility; prejudicial	Summation referencing aliases prejudicial; improper under 405(a) and 608
Harmless error analysis	Alias evidence did not affect outcome; no reversible error	Credibility hinge made improper impeachment outcome-determinative	Error not harmless; requires reversal and new trial

State v. Salaam, 225 N.J. Super. 66 (App. Div. 1988) (alias evidence requires tangible prejudice for reversal)
State v. Jenkins, 299 N.J. Super. 61 (App. Div. 1997) (probation violations cannot be used as convictions for impeachment)
State v. Burgos, 262 N.J. Super. 1 (App. Div. 1992) (charges dismissed under plea cannot be used to impeach credibility)
State v. Guenther, 181 N.J. 129 (2004) (limits on using opinions, reputation, or prior convictions to attack credibility)
State v. Rowe, 57 N.J. 293 (1970) (only convictions can be used for impeachment under 609; ancillary events not allowed)
State v. Garvin, 44 N.J. 268 (1965) (earlier broad dicta on using judgment records for impeachment; modern limits apply)