State v. William A. Case, Jr. (072688), 103 A.3d 237

Background

Defendant (waived jury) engaged in multiple sexually explicit instant-message chats with an undercover law‑enforcement officer posing as a 14‑year‑old "Amanda," and traveled to a prearranged meeting where he was arrested. Convicted at a bench trial of attempted luring (second degree), attempted child endangerment (third degree), and attempted criminal sexual contact (fourth degree).
Defendant presented a diminished‑capacity defense supported by three defense mental‑health experts diagnosing PTSD and depression; State’s expert testified defendant engaged in purposeful, goal‑directed behavior toward a sexual liaison.
At sentencing the trial judge found only mitigating factor 7 (no prior criminal history) but found aggravating factors 3 (risk of reoffense) and 9 (need for deterrence), gave concurrent terms resulting in an aggregate 8‑year sentence with a 4‑year discretionary parole disqualifier, plus lifetime parole supervision and sex‑offender registration.
Appellate Division affirmed. Supreme Court granted certification limited to whether the discretionary parole disqualifier was properly imposed.
New Jersey Supreme Court vacated the sentence and remanded for resentencing because (1) the finding of aggravating factor 3 was not supported by credible record evidence (court relied on speculation about prior targeting of minors), (2) the court failed adequately to explain the weight given to aggravating factor 9, (3) the court did not address or explain rejection of most proffered mitigating factors, and (4) the court did not perform the required qualitative balancing (including the heightened standard) necessary before imposing a parole disqualifier.
The Court directed a new sentencing proceeding within 30 days, permitting up‑to‑date evidence on defendant’s conduct and rehabilitation and requiring competent, credible support for any sentencing findings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly imposed a discretionary parole disqualifier (did aggravating factors clearly and convincingly substantially outweigh mitigating factors and were findings supported by credible evidence)	The sentencing judge made fact findings supported by the record and reasonably gave weight to aggravating factors, justifying the four‑year parole disqualifier	The court speculatively relied on unsupported assumptions (prior online targeting of minors), ignored or failed to weigh numerous mitigating factors, and did not articulate the qualitative balancing required for a parole disqualifier	Vacated sentence and remanded for resentencing: aggravating factor 3 lacked credible support; court failed to explain weight given to factor 9; did not adequately address or explain rejection of many mitigating factors; no proper qualitative balancing or clear‑and‑convincing showing for parole disqualifier

Key Cases Cited

State v. Natale, 184 N.J. 458 (explaining Code’s goal of uniform sentencing and that balancing drives placement within statutory range)
State v. Fuentes, 217 N.J. 57 (trial judge must identify, support, and weigh aggravating/mitigating factors and explain sentencing rationale)
State v. Roth, 95 N.J. 334 (findings of factors must be supported by competent, credible evidence)
State v. Kruse, 105 N.J. 354 (heightened standard and required articulation when imposing parole disqualifier)
State v. Blackmon, 202 N.J. 283 (mitigating factors called to the court’s attention should not be ignored)
State v. Dalziel, 182 N.J. 494 (mitigating factors amply based in record must be found)
State v. Pierce, 188 N.J. 155 (range of sentences available when mitigating factors are credited)
State v. Megargel, 143 N.J. 484 (mitigating factors can justify sentence as if one degree lower)
State v. Jarbath, 114 N.J. 394 (discussion of deterrence and its relative penal value)
State v. Lawless, 214 N.J. 594 (deferential appellate review applies when sentencing procedures are followed)
State v. Randolph, 210 N.J. 330 (resentencing court may consider intervening conduct and rehabilitation)
State v. Gardner, 113 N.J. 510 (distinguishing specific and general deterrence)