State v. Vonte Skinner (071764)
218 N.J. 496
| N.J. | 2014Background
- Snr. criminal case where Skinner was charged with attempted murder and related offenses; notebooks in Skinner’s car contained violent rap lyrics authored by him; many lyrics predated the incident; trial court admitted redacted lyrics under N.J.R.E. 404(b) to show motive/intent; first trial ended in mistrial, retrial followed; at retrial the State read lengthy lyrics to jurors; defendant argued lyrics were not probative and overly prejudicial; appellate division reversed, leading to this Supreme Court review; court held lyrics were highly prejudicial with little probative value for motive/intent, requiring retrial and redaction guidance; decision limits use of artistic expressions as 404(b) evidence unless a strong nexus to the charged offense exists.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 404(b) applies to artistic lyrics | State treated lyrics as 404(b) evidence for motive/intent | Lyrics are not 404(b) acts; prejudicial | No; lyrics not probative and prejudicial under 404(b). |
| Do lyrics have strong nexus to the offense? | Lyrics illuminate defendant’s motive as enforcer | No direct nexus; lyrics fiction | No; lack of strong nexus; probative value outweighed by prejudice. |
| Was prosecutorial closing argument improper? | Closing tied to evidence and themes | Limited or improper inflammatory rhetoric | retrial required; court cautions against inflammatory calls to arms. |
| Should the lyric evidence be admitted with safeguards? | Redacted content sufficient | Redaction inadequate; still prejudicial | If admitted, must be tightly redacted and carefully limited to probative content. |
Key Cases Cited
- State v. Koskovich, 168 N.J. 448 (2001) (admission of lyrics to prove motive/intent in homicide case justified under Cofield framework)
- State v. Cofield, 127 N.J. 328 (1992) (four-part Cofield test to assess 404(b) admissibility)
- State v. Covell, 157 N.J. 554 (1999) (motive/intent evidence must be relevant and weighed for prejudice)
- State v. Rose, 206 N.J. 141 (2011) (404(b) as exclusionary safeguard against prejudice; consider alternatives)