State v. Rangel
213 N.J. 500
| N.J. | 2013Background
- Defendant Erie Rangel was charged with first-degree aggravated sexual assault under N.J.S.A. 2C:14-2(a)(3) and related offenses.
- The underlying incident occurred April 22, 2007, where P.F., 18, was attacked, restrained, and subjected to vaginal contact during an assault.
- P.F. sustained facial injuries, a base-of-nose fracture, swelling, and school-day disruptions; medical examination followed at a hospital.
- Trial court denied a judgment of acquittal on the (a)(3) count; Appellate Division later reversed and acquitted on (a)(3).
- State sought certification; this Court granted to resolve whether 'aggravated assault on another' targets a third party or the victim.
- The Court held that 'on another' refers to a person other than the victim and affirmed acquittals on (a)(3) offenses, remanding for resentencing on remaining convictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of 'aggravated assault on another' in (a)(3) | Rangel argued it includes the victim. | Rangel argued it refers to a third person. | 'On another' refers to a third person. |
| Does (a)(3) redundancy conflict with (a)(6)'s severe injury requirement | Interpretation includes victim to avoid redundancy. | Victim reading would render (a)(6) meaningless. | Textual reading preserves distinct purposes of (a)(3) and (a)(6). |
| Relation to merger jurisprudence and Cole | Cole supports the State's position on broader reading. | Cole is irrelevant to the (a)(3) interpretation | Cole has no precedential value for this issue. |
| What is the proper interpretive approach | Text and context should give meaning consistent with statute as a whole. | Extrinsic aids may be necessary if ambiguity exists. | Plain reading, in context, yields no ambiguity; lenity not needed. |
Key Cases Cited
- Gelman v. State, 195 N.J. 475 (N.J. 2008) (ambiguity resolved in favor of stated objective; statutory interpretation guide)
- Regis v. State, 208 N.J. 439 (N.J. 2011) (structure and coherence of statutory scheme; avoid redundancy)
- DiProspero v. Penn, 183 N.J. 477 (N.J. 2005) (preferred aid for interpreting statutes with multiple provisions)
- State v. Rangel, 422 N.J. Super. 1 (App.Div.2011) (Appellate Division held 'on another' refers to third party; relied on for certification history)
- State v. Cole, 120 N.J. 321 (N.J. 1990) (merger-focused; not controlling on the meaning of (a)(3) here)