State v. Sanchez-Medina, 176 A.3d 788

Defendant Alexis Sanchez‑Medina was tried and convicted of multiple sexual‑assault offenses arising from four separate incidents involving four victims; only one victim (R.D.) identified him.
Police detained and interrogated defendant; he admitted to some contact in several interviews but denied core allegations and later recanted at trial.
On cross‑examination the prosecutor asked whether defendant came to the U.S. legally; defendant said he had not. The State now concedes that questioning was improper.
The trial court gave conflicting limiting instructions about immigration testimony and did not strike the testimony from the record.
Neither party requested, and the court did not give, a jury charge on evaluating eyewitness identifications, despite R.D.’s identification being central and contested.
Appellate Division gave mixed rulings; the Supreme Court granted certification on (1) admissibility of immigration status for impeachment and (2) failure to instruct on eyewitness identification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of defendant’s immigration status on cross‑examination	State: Evidence was improper but not prejudicial; limiting instructions cured any error	Sanchez‑Medina: Immigration status was irrelevant, highly prejudicial, and impeachment questioning plus flawed instructions denied a fair trial	Error to elicit immigration status; generally inadmissible because irrelevant and unduly prejudicial; here the testimony and conflicting instructions were significant and should have been excluded or clearly stricken
Failure to give jury charge on eyewitness identification	State: Omission not plain error because of corroborating evidence, including defendant’s statements	Sanchez‑Medina: Identification was the key contested issue (only one witness identified him); jury needed Henderson/Cotto guidance to evaluate reliability	Court held the charge was required when identification is a key issue; omission was reversible error because R.D.’s in‑court ID was central and the overall proof was not overwhelming
Cumulative error (combined effect of both issues)	State: Individual errors harmless; no new trial needed	Sanchez‑Medina: Combined errors undermined fairness and verdict	Court found cumulative effect denied fair trial; vacated convictions and remanded for new trial

Miranda v. Arizona, 384 U.S. 436 (Sup. Ct.) (Miranda‑warning principles governing custodial interrogation)
State v. Henderson, 208 N.J. 208 (N.J. 2011) (sets estimator variables and directs model eyewitness ID jury charges)
State v. Cotto, 182 N.J. 316 (N.J. 2005) (trial court must instruct when eyewitness ID is a key issue)
State v. Cromedy, 158 N.J. 112 (N.J. 1999) (cross‑racial identification reliability; required jury guidance in appropriate cases)
State v. Romero, 191 N.J. 59 (N.J. 2007) (jury must be informed that witness confidence is not always a reliable indicator of accuracy)
State v. Jenewicz, 193 N.J. 440 (N.J. 2008) (cumulative‑error analysis can require reversal even if single errors are insufficient)