Craig Szemple v. Morris County Prosecutor's Office

CourtNew Jersey Superior Court Appellate Division
DecidedAugust 19, 2024
DocketA-0181-22
StatusUnpublished

This text of Craig Szemple v. Morris County Prosecutor's Office (Craig Szemple v. Morris County Prosecutor's Office) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craig Szemple v. Morris County Prosecutor's Office, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0181-22

CRAIG SZEMPLE,

Plaintiff-Appellant,

v.

MORRIS COUNTY PROSECUTOR'S OFFICE,

Defendant-Respondent. _________________________

Submitted May 7, 2024 – Decided August 19, 2024

Before Judges Rose and Smith.

On appeal from the Superior Court of New Jersey, Law Division, Morris County, Docket No. L-0560-22.

Craig Szemple, appellant pro se.

Inglesino Taylor, attorneys for respondent (Justin A. Marchetta and Graham K. Staton, of counsel and on the brief).

PER CURIAM In this appeal we consider an individual's right to obtain records after

conclusion of all phases of their criminal proceeding under both the Open Public

Records Act (OPRA), N.J.S.A. 47:1A-1 to -13, and the common law right of

access. After review of the record and consideration of the applicable legal

principles, we affirm.

I.

A.

The relevant facts underlying defendant's conviction were set forth by our

Supreme Court in State v. Szemple, 247 N.J. 82, 90 (2021) (holding the State

was not required to produce the post-conviction discovery sought by defendant).

Nicholas Mirov disappeared in 1975. Four months after his disappearance, police discovered a body in the woods. Police did not identify the body until 1991, after defendant's brother, when questioned about a separate homicide, revealed that defendant Craig Szemple had admitted to killing Mirov.

Defendant was charged in 1991 with the first- degree murder of Mirov. At his first trial in 1992, after the State rested, Michael Boyle . . . , defendant's then father-in-law, produced a letter (the Boyle letter or the letter) believed to be written by defendant to his then- wife, Theresa Boyle Szemple . . . , admitting to Mirov's murder.

....

A-0181-22 2 Boyle claimed that he discovered the unsigned letter in April 1991, sticking out of a box, while helping his daughter—defendant's then-wife, . . . move out of the marital home. Boyle believed that the incriminating letter was written by defendant to Theresa. The letter began, "[d]earest companion and trusted (new) wife."

According to Boyle, after finding the letter, he hid it, without telling his daughter. He waited over a year to disclose the letter that he believed was a confession to a murder because, he claimed, his ex-wife checked with an attorney who told her that the prosecution had sufficient evidence to convict defendant. That attorney, however, testified that he never had such a conversation with Boyle's ex-wife.

Defendant's first trial ended in a mistrial. When he was re-tried in 1994, the State introduced the letter as a key piece of evidence, arguing that in the letter defendant confided to his wife that he had murdered Mirov. The State, however, did not call Theresa as a witness. Instead, the State relied on a handwriting expert who opined that the letter was written by defendant. The State also presented the testimony of one of defendant's brothers, who asserted that defendant had confessed to him in 1975 that he had murdered Mirov.

Defendant took the stand and denied any involvement in Mirov's death or writing the confession letter to Theresa. He testified that his father made him the "heir apparent" to the family business and that the letter was likely manufactured by his brothers in a plot to frame him so that they could gain his share of his father's inheritance.

The jury convicted defendant.

A-0181-22 3 Whether investigators had interviewed Theresa about the letter allegedly written to her or whether the prosecutor's office withheld discovery on that subject was not an issue raised on defendant's direct appeal or in his post-conviction relief (PCR) proceeding.

[Id. at 87, 114-15.]

In 2016, defendant for the first time requested "copies of any statements

or reports memorializing interviews with Theresa following Michael's

production of the Boyle letter" from the Morris County Prosecutor's Office

(MCPO). The MCPO denied the request on the grounds that "defendant had no

right to post-conviction discovery" under State v. Marshall, 148 N.J. 89 (1997).

On January 19, 2018, defendant filed a motion to compel the disclosure

of exculpatory evidence necessary for defendant to file a motion for a new trial.

After hearing defendant's motion, the trial court denied it. On appeal, we

reversed, "concluding that the State's obligation to produce discovery continued

post-conviction under Rule 3:13-3(b)(1)(F) and (G) and the constitutional

requirement to disclose exculpatory evidence under Brady v. Maryland."

Szemple, 247 N.J. at 88 (internal citations omitted). In a 4-3 decision, our

Supreme Court reversed, and affirmed the trial court's denial of the motion.

Applying an abuse of discretion standard, the Court stated that although the trial

court miscategorized defendant's new trial motion as a second PCR petition, the

A-0181-22 4 motion still must fail "because defendant cannot satisfy the 'reasonable

diligence' requirement common to both motions." Id. at 100. Writing for the

majority, Justice Solomon explained,

[D]efendant's discovery request came decades after defendant learned about the ground upon which his request is based, and defendant failed to take any action upon that knowledge over the years and over the course of judicial proceedings focused on the letter's admissibility.

Nor has defendant made any showing that discovery should be granted in the interest of justice because a record of the hypothetical interview might constitute exculpatory evidence. Although the title of defendant's motion invokes Brady,[1] defendant has not put forward any evidence in support of his claim that the information sought could be exculpatory or material.

[Ibid.]

The Court noted that while the discovery sought was limited and specific,

"defendant has failed to support his discovery request with any explanation of

his failure to raise the present issue before the trial court, during direct appeal,

or at the time of his first PCR." Id. at 109.

1 Brady v. Maryland, 373 U.S. 83 (1963). A-0181-22 5 In his dissent, Justice Albin concluded that defendant's "particularized

request for discovery in this case," was in line with our State's "open-file"

approach to discovery. He reasoned that:

[a] system of post-conviction relief cannot fulfill its true purpose if reasonable, relevant, and non- burdensome requests for discovery can be thwarted by a prosecutor's office intent on keeping from view discovery that was or should have been available pretrial. See R. 3:13-3(b)(1). Our system of justice should have nothing to fear from the dissemination of relevant information to the defense.

[Id. at 113.]

B.

On January 12, 2022, after our Supreme Court's decision in Szemple was

issued, plaintiff submitted both an OPRA and a common law public records

request to the MCPO seeking certain records pertaining to Nicholas Mirov's

murder investigation. Plaintiff submitted the following twelve requests:

1.

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Craig Szemple v. Morris County Prosecutor's Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-szemple-v-morris-county-prosecutors-office-njsuperctappdiv-2024.