In the Matter of the Appeal of the Denial of the Application for Firearms Purchaser Identification Card, Etc.

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 19, 2026
DocketA-1257-24
StatusUnpublished

This text of In the Matter of the Appeal of the Denial of the Application for Firearms Purchaser Identification Card, Etc. (In the Matter of the Appeal of the Denial of the Application for Firearms Purchaser Identification Card, Etc.) 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
In the Matter of the Appeal of the Denial of the Application for Firearms Purchaser Identification Card, Etc., (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1257-24

IN THE MATTER OF THE APPEAL OF THE DENIAL OF THE APPLICATION FOR FIREARMS PURCHASER IDENTIFICATION CARD AND PERMITS TO PURCHASE A HANDGUN TO VINCENT P. CASSARINO. ___________________________

Submitted December 10, 2025 – Decided March 19, 2026

Before Judges Paganelli and Jacobs.

On appeal from the Superior Court of New Jersey, Law Division, Ocean County, Docket No. GPA-005-24.

Zohn & Zohn, LLP, attorney for appellant Vincent P. Cassarino (Edward J. Zohn, on the briefs).

Citta, Holzapfel & Zabarsky, attorneys for respondent Borough of Seaside Park (Barry A. Stieber and Steven A. Zabarsky, on the brief).

PER CURIAM

Vincent P. Cassarino appeals from a November 21, 2024 order upholding

a municipal police chief's denial of his application for a New Jersey Firearms Purchaser Identification Card (FPIC) and a Handgun Purchase Permit (HPP).

We affirm, substantially for the reasons expressed in Judge David M. Fritch's

well-reasoned decision.

I.

We derive the following facts from the hearing and other portions of the

record. On March 14, 2022, Cassarino applied to the Seaside Park Police

Department (SPPD) for an FPIC and HPP. A SPPD officer conducted a

background investigation, uncovering a twenty-year history of law enforcement

encounters, including:

• A 2003 conviction for disorderly conduct, N.J.S.A. 2C:33-2(a), from an arrest in Toms River for "creating a loud and profanity[-]filled disturbance in [an] emergency room, and refusing to leave when asked to do so by security."

• A 2004 conviction for driving while intoxicated (DWI), N.J.S.A. 39:4-50.

• A 2004 arrest in Ocean Township for possession of controlled dangerous substance (CDS), prescription legend drugs without a prescription, N.J.S.A. 2C:35-10.5(b); possession of CDS, N.J.S.A. 2C:35-10(a)(1); possession of prescription drugs not in original container, N.J.S.A. 2C:35- 24; and disorderly conduct, N.J.S.A. 2C:33-2(a)(1), disposed by way of pre-trial intervention (PTI) in 2006.

• A 2018 DWI arrest in Seaside Heights, resolved by guilty plea to refusal to submit to breath testing, N.J.S.A. 39:4-50.2.

• A 2021 conviction for violation of a municipal ordinance, public nuisance, in Seaside Heights, stemming from an arrest for defiant trespass, N.J.S.A. 2C:18-3(b).

A-1257-24 2 On August 1, 2024, the SPPD Chief denied the application, citing N.J.S.A.

2C:58-3(c)(5) ("[I]ssuance would not be in the interest of the public health,

safety or welfare."). Cassarino appealed to the Law Division.

Judge Fritch conducted a plenary hearing on November 20, 2024. The

officer who performed the background check and the SPPD Chief testified for

the Borough of Seaside Park (Borough). Their testimony encompassed incidents

involving Cassarino's contact with law enforcement agencies besides SPPD.

Cassarino testified on his own behalf.

On November 21, the judge affirmed the denial in an eleven-page written

opinion and accompanying order. In his decision, Judge Fritch considered both

testimonial evidence and documentary exhibits, including the police

investigation file, court records, and incident reports. He found by a

preponderance of the evidence that Cassarino's criminal history demonstrated a

lack of self-control, poor judgment, and "disregard for public safety," and that

granting the permits would be contrary to the public interest.

On appeal, Cassarino argues the judge erred in upholding the denial. He

maintains his criminal history is "minimal" and non-violent, consisting largely

of arrests or incidents that did not lead to convictions. He disputes the factual

basis for several of those incidents, asserting they were misunderstandings or

A-1257-24 3 otherwise benign. Cassarino further contends the judge improperly relied on

hearsay contained in police reports, preventing his counsel from cross-

examining the relevant witnesses. As a result, Cassarino asserts, "we shall never

know which parts of the evidence the SPPD believes should be admitted under

N.J.R.E. 803(c)(6)."

The Borough defends the denial, emphasizing the number and nature of

Cassarino's offenses and law enforcement contacts. It argues that under New

Jersey law, disorderly persons convictions and evidence of substance abuse,

even in the absence of indictable convictions, may support denial under the

"public health, safety or welfare" provision. The Borough maintains the court

properly considered the totality of the evidence, including live testimony,

standardized records, and Cassarino's credibility.

II.

"We review a trial court's legal conclusions regarding firearms licenses de

novo." In re N.J. Firearms Purchaser Identification Card by Z.K., 440 N.J.

Super. 394, 397 (App. Div. 2015) (citing In re Sportsman's Rendezvous Retail

Firearms Dealer's License, 374 N.J. Super. 565, 575 (App. Div. 2005)).

However, appellate review of a trial court's factual findings on such matters is

"limited." In re Z.L., 440 N.J. Super. 351, 355 (App. Div. 2015). "Ordinarily,

A-1257-24 4 an appellate court should accept a trial court's findings of fact that are supported

by substantial credible evidence." In re Return of Weapons to J.W.D., 149 N.J.

108, 116-17 (1997) (citing Bonnco Petrol, Inc. v. Epstein, 115 N.J. 599, 607

(1989)). Even so, the record should be sufficiently complete and definitive to

support such factual findings. See id. at 117.

Because of the importance of developing an appropriate record to generate

factual findings, the statutory scheme has been interpreted to call for evidentiary

hearings in the Law Division to prove or disprove the critical facts bearing on a

contested permit application. See In re Dubov, 410 N.J. Super. 190, 200 (App.

Div. 2009) (noting "the informality of a chief of police's initial consideration of

an application for a gun permit requires an evidentiary hearing when an

applicant appeals a denial to the [Superior] Court"); see also Weston v. State,

60 N.J. 36, 45 (1972). "The court may consider hearsay but may not base its

decision upon hearsay alone." Matter of M.U.'s Application for a Handgun

Purchase Permit, 475 N.J. Super. 148, 173 (App. Div. 2023) (citing Weston, 60

N.J. at 50-52).

The police chief bears the burden of proving good cause for denial by a

preponderance of the evidence. N.J.S.A. 2C:58-3(c), (d); In re Osworth, 365

N.J. Super. 72, 77 (App. Div. 2003).

A-1257-24 5 N.J.S.A. 2C:58-3(c)(5) permits denial if "issuance would not be in the

interest of the public health, safety, or welfare [,]" even absent specific statutory

bar. Osworth, 365 N.J. Super. at 79 (quoting Burton v. Sills, 53 N.J. 86, 91

(1968)). This standard includes cases of "individual unfitness" where the

applicant's background demonstrates a risk to the community. Ibid. (quoting

Burton, 53 N.J. at 91).

Judge Fritch found Cassarino's testimony to be self-serving and not

credible throughout. He wrote:

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Related

In Re Sportsman's Firearms License
866 A.2d 195 (New Jersey Superior Court App Division, 2005)
BURTON v. Sills
248 A.2d 521 (Supreme Court of New Jersey, 1968)
In Re Dubov
981 A.2d 87 (New Jersey Superior Court App Division, 2009)
Bonnco Petrol, Inc. v. Epstein
560 A.2d 655 (Supreme Court of New Jersey, 1989)
Bustamante v. Borough of Paramus
994 A.2d 573 (New Jersey Superior Court App Division, 2010)
Weston v. State
286 A.2d 43 (Supreme Court of New Jersey, 1972)
In Re Osworth
838 A.2d 465 (New Jersey Superior Court App Division, 2003)
In re Z.L.
113 A.3d 791 (New Jersey Superior Court App Division, 2015)
In re Z.K.
114 A.3d 362 (New Jersey Superior Court App Division, 2015)
In re Return of Weapons to J.W.D.
693 A.2d 92 (Supreme Court of New Jersey, 1997)

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