State v. R.J.M., 180 A.3d 1201

Defendant (R.J.M.) was convicted of first-degree sexual assault in 1990 and released from prison in 2000; thereafter he was civilly committed under the Sexually Violent Predator Act (SVPA) to the Special Treatment Unit (STU).
In 2014, while confined at the STU, defendant was charged with terroristic threats, resisting arrest, obstruction, and aggravated assault based on an incident with corrections officers.
At the 2016 trial, the State sought a Sands hearing to permit impeachment of defendant with his 1990 conviction if he testified, arguing SVPA commitment counts as "confinement" under N.J.R.E. 609(b)(1).
The trial court agreed that SVPA civil commitment extended the ten-year period in N.J.R.E. 609(b)(1) (making the conviction non-remote) and, alternatively, found the conviction admissible under the remote-conviction balancing test.
Defendant declined to testify because of the impeachment ruling; he was convicted of terroristic threats and obstruction, acquitted of assault, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether time in SVPA civil commitment counts as "confinement for" the predicate conviction under N.J.R.E. 609(b)(1)	"Confinement" is broad and includes civil commitment, so the ten-year clock has not run	SVPA commitment is civil, not confinement "for" the criminal conviction; the custodial sentence ended in 2000 so the conviction is remote	Reversed trial court: SVPA commitment is not confinement "for" the conviction; the ten-year period ran from release in 2000, so the conviction was remote
If conviction is remote, whether the State met its burden under N.J.R.E. 609(b)(1) to show probative value outweighs prejudice	The seriousness of the predicate crime justifies admission despite remoteness	The conviction is very remote, unrelated to honesty/credibility, and cumulative prejudice (STU context) weighs against admission	Trial court erred: State did not carry burden; court improperly emphasized seriousness without balancing probative value vs. prejudice
Whether the evidentiary error was harmless	Admission would not have affected outcome because other evidence supported conviction	The ruling chilled defendant's right to testify; credibility was central and error could have affected verdict	Error was not harmless; reversal and remand for retrial required

State v. T.J.M., 220 N.J. 220 (discussing abuse-of-discretion standard for evidentiary rulings)
State v. Rose, 206 N.J. 141 (courts do not defer to rulings based on mistaken interpretation of evidence rules)
State v. Bellamy, 178 N.J. 127 (SVPA commitment does not automatically flow from a predicate conviction)
Kansas v. Crane, 534 U.S. 407 (civil commitment requires proof of current dangerousness and a qualifying mental condition)
State v. Paige, 256 N.J. Super. 362 (pre-N.J.R.E. 609(b) precedent; relied on by trial court but inapposite post-rule)