History
  • No items yet
midpage
State v. McGuire
16 A.3d 411
| N.J. Super. Ct. App. Div. | 2011
Read the full case

Background

  • McGuire was convicted of first-degree murder, desecration of human remains, and two other charges, and sentenced to life with no parole for 63 years 9 months plus concurrent 10 years for desecration and 5 years for perjury.
  • Body was found in Virginia in May 2004, cut into three pieces, wrapped in bags, and dumped; the attestments linked to McGuire through motive and conduct before and after disappearance.
  • The State’s case relied on circumstantial and forensic evidence, including gun purchase in Pennsylvania, internet searches about poisons and murder, cell phone and EZ Pass records, handwriting and linguistics analyses, and surveillance data.
  • Defense challenged the admissibility and weight of expert testimony on garbage-bag comparisons and sought to admit other evidence; the court admitted certain expert testimony and limited defense evidence.
  • On appeal, McGuire argued juror taint, prosecutorial misconduct, evidentiary errors, and improper sentencing procedures; the Appellate Division affirmed the conviction and sentence.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Jury taint by media and deliberations State contends jurors exposed to inflammatory coverage McGuire asserts prejudicial influence tainted deliberations No reversible error; no substantial likelihood of undue prejudice; voir dire and post-trial juror interviews support fairness.
Prosecutorial misconduct during summation State argues evidence supported conclusions; closing remarks within bounds McGuire claims improper and speculative inferences based on excluded evidence No plain error; isolated remarks not capable of producing unjust result given total evidence.
Admissibility of garbage-bag tool-mark testimony Lesniak’s tool-mark analysis shows same-source bags Challenge to methodology and reliance on NAS critique Admissible as expert testimony; even if excluded, harmless error due to duplicate testimony by Ruiz.
Limitation of defense witnesses and evidence Defense testimony about Bill’s past marriage and gun issues irrelevant Such testimony would illuminate defendant’s state of mind and motive Trial court did not abuse discretion under N.J.R.E. 403; excluding it was not error.
Sentencing determinations and aggravating factor one State argues substantial premeditation and depravity McGuire disputes factors and weight Aggravating factor one properly found; sentence affirmed.

Key Cases Cited

  • State v. Harvey, 151 N.J. 117 (1997) (reliability and admissibility of expert testimony; Frye standard applied in NJ)
  • State v. Chun, 194 N.J. 54 (2008) (Frye standard; general acceptance of scientific evidence)
  • State v. Macon, 57 N.J. 325 (1971) (plain error and harmless error review framework)
  • Ramirez v. State, 810 So.2d 836 (Fla. 2001) (tool-mark/jurisdictional acceptance of forensic testimony)
  • State v. Behn, 375 N.J. Super. 409 (App. Div. 2005) (admissibility of scientific evidence; NAS critique acknowledges but not excludes)
  • State v. Ross, 249 N.J. Super. 246 (App. Div. 1991) (prosecutorial misconduct and limitation of evidence in summation)
Read the full case

Case Details

Case Name: State v. McGuire
Court Name: New Jersey Superior Court Appellate Division
Date Published: Mar 16, 2011
Citation: 16 A.3d 411
Docket Number: A-6576-06T4
Court Abbreviation: N.J. Super. Ct. App. Div.