State v. Robert Goodwin(074352)
129 A.3d 316
N.J.2016Background
- Defendant Robert Goodwin lived with girlfriend Stacey; Stacey owned and insured a 1999 Chevy Tahoe with Progressive; Goodwin was primary driver and co-signer on the loan.
- On Sept. 13, 2009 Goodwin drove the Tahoe to see another woman (Linda); the vehicle was later found burned on a different street; investigators concluded arson and that the ignition key had been used.
- Goodwin told Stacey and police the SUV had been stolen; Stacey filed theft and fire claims with Progressive; later, under investigation, Goodwin admitted he had parked the SUV where it was found and initially lied to conceal an affair; he denied setting the fire.
- Progressive’s investigator found the misrepresentations undermined verifiability and denied the claim; criminal indictment charged arson, attempted theft by deception, and insurance fraud under N.J.S.A. 2C:21-4.6(a).
- Jury convicted Goodwin of second-degree insurance fraud but acquitted him of arson and attempted theft; Appellate Division reversed the fraud conviction, reasoning that liability required insurer reliance or a predicate conviction; State appealed to the New Jersey Supreme Court.
- Supreme Court reversed the Appellate Division, reinstated the insurance-fraud conviction, and remanded for entry of judgment consistent with its opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether N.J.S.A. 2C:21-4.6(a) requires insurer reliance or actual payment for conviction | State: Liability attaches if false statement could have reasonably affected insurer’s decision, even if claim was ultimately denied | Goodwin: "Material" requires prejudice to insurer or exposure to liability; no payment/no prejudice => no fraud | Court: No reliance/payment requirement; materiality means capable of influencing insurer’s decision; conviction stands |
| Definition of "material fact" under the statute | State: Should follow ordinary meaning/capacity-to-influence standard used in perjury and federal false-statement law | Goodwin: Ambiguity should be resolved in defendant’s favor; materiality requires actual harm | Court: Adopts capacity-to-influence definition (consistent with perjury statute and federal law); approves narrowed Model Jury Charge wording |
| Whether insurance-fraud conviction required predicate conviction of arson or theft | State: No predicate offense required; insurance-fraud is independent and focuses on false statements regarding a claim | Goodwin: Jury’s acquittals on arson/theft validate truth and preclude fraud conviction | Court: Rejects predicate requirement; acquittals do not bar fraud conviction; inconsistent verdicts allowed and not grounds to overturn here |
| Effect of de minimis dismissal provision on materiality standard | State: De minimis clause is a safety valve, not a signal that actual insurer prejudice is required | Goodwin: Presence of de minimis clause shows Legislature intended to criminalize only cases causing/threatening real harm | Court: De minimis provision allows dismissal of trivial cases but does not alter materiality standard or require insurer reliance |
Key Cases Cited
- Kungys v. United States, 485 U.S. 759 (defining material falsehood as capable of influencing decisionmaker)
- Longobardi v. Chubb Ins. Co. of N.J., 121 N.J. 530 (civil definition of an insured’s misstatement as material if a reasonable insurer would consider it relevant)
- State v. Banko, 182 N.J. 44 (recognizing acceptance of inconsistent jury verdicts)
- State v. Muhammad, 182 N.J. 551 (standard for reviewing sufficiency of evidence to support jury verdict)