Margaret Sudhakar v. New Jersey State Police

CourtNew Jersey Superior Court Appellate Division
DecidedDecember 23, 2024
DocketA-1764-22
StatusUnpublished

This text of Margaret Sudhakar v. New Jersey State Police (Margaret Sudhakar v. New Jersey State Police) 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
Margaret Sudhakar v. New Jersey State Police, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-1764-22

MARGARET SUDHAKAR,

Plaintiff-Appellant,

v.

NEW JERSEY STATE POLICE and NEW JERSEY ATTORNEY GENERAL,

Defendants-Respondents,

and

GOVERNOR PHIL MURPHY,

Defendant. ___________________________

Argued October 29, 2024 – Decided December 23, 2024

Before Judges Smith, Chase and Vanek.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County Docket No. L-1706-22.

Kurt W. Perhach (Elm Ridge Legal Consulting) argued the cause for appellant. Vivek N. Mehta, Deputy Attorney General, argued the cause for respondents (Matthew J. Platkin, Attorney General, attorney; Sara M. Gregory, Assistant Attorney General, of counsel; Emily M. Bisnauth, Vivek N. Mehta and Daniel W. Knox, Deputy Attorneys General, on the brief).

PER CURIAM

Plaintiff Margaret Sudhakar appeals a trial court order denying her order

to show cause (OTSC) and dismissing her complaint against defendants New

Jersey State Police (NJSP), the New Jersey Attorney General (the AG), and

Governor Phil Murphy alleging the denial of requests to perform DNA testing

on historical documents from the Lindbergh kidnapping case constitutes a

violation of the Open Public Records Act (OPRA), N.J.S.A. 47:1A-1 to 13, the

common law right of access, and Governor Brendan Byrne's Executive Order

110. After a thorough review of the record and our jurisprudence, we affirm.

I.

We glean the salient facts relevant to our disposition from the record.

This appeal centers on plaintiff's search for DNA evidence related to the

kidnapping of infant Charles A. Lindbergh, Jr. on March 1, 1932. Between the

kidnapping and the discovery of the infant's body, an unidentified individual

sent numerous ransom notes to the Lindbergh family home. After law

enforcement investigations, Bruno Richard Hauptmann was tried, convicted,

A-1764-22 2 and ultimately executed in 1936 for the kidnapping and murder of the infant.

Hauptmann proclaimed his innocence up until his death.

The NJSP Museum & Learning Center (the Museum) is the repository of

the NJSP's historical recordings, including approximately 225,000 documents

and other materials related to the Lindbergh case. Due to continued interest in

the case, Governor Brendan Byrne signed Executive Order 110 (the EO) on

October 9, 1981, providing the public with conditional access to evidence

associated with the Lindbergh case. Acknowledging that reasonable measures

needed to be implemented to ensure preservation of these historical items, the

EO authorized the Superintendent of the NJSP to establish procedures to

protect the files, records, and exhibits from the risk of damage or mutilation,

while allowing the public to examine, inspect, and copy them.

The NJSP maintains the historical items in a temperature and humidity

controlled locked room with monitored access. Evidence envelopes and their

contents are housed in polyester sleeves to allow individuals to inspect the

items without directly touching the artifacts or transferring any foreign

substance to them. Those sleeves are retained in manuscript folders encased in

archival boxes, both of which are acid-free.

On March 2, 2022, film director and producer Michael Braverman sent a

A-1764-22 3 letter to the NJSP by email, seeking permission to extract DNA through

undescribed "non-evasive"1 testing of fourteen envelopes, eleven stamps and a

piece of wood from the historical repository maintained by the NJSP under the

EO. Braverman did not describe how the DNA samples would be extracted

from the artifacts without damaging or altering them in any way. One week

later, the NJSP denied the request.

Braverman forwarded a similar request to the Governor's Office, which

responded that it was not the custodian of the items being sought. Braverman

then sent a July 19 email to "Frank Caruso/Gov. Records 609-292-6830," the

Executive Director of the Government Records Council (GRC), requesting

permission to accomplish DNA testing of items in the NJSP Museum. The

OAG's records custodian never received that request and no proof of delivery

to the OAG was submitted to the trial court.

On September 28, 2022, plaintiff filed a verified complaint in lieu of

prerogative writs and OTSC, alleging a violation of OPRA, the common law

right of access, and the EO, requesting that the court compel the DNA testing

of the envelopes and stamps maintained by the NJSP related to the Lindbergh

1 Neither party offered a definition of "non-evasive." A-1764-22 4 kidnapping.2 Braverman was not a plaintiff on the filing.

The OTSC was coupled with a letter from a forensic biology specialist,

Arthur Young of Guardian Forensics, describing the methodology for the DNA

testing he proposed to undertake to determine whether Hauptmann had licked

the stamps and sealed the envelopes of the ransom letters sent to the Lindbergh

home. Although Young characterized his untested "canned-air technique" for

extracting DNA samples from the envelopes and stamps as "non-destructive,"

the technique required him to "neutraliz[e]" the adhesive on the historical

artifacts by directly applying a chemical fluid to expose approximately ninety

percent of the back flap of each envelope and the back of each stamp . After

removal of a portion of the adhesive on the historical document and swabbing

for DNA, he then proposed to reattach the envelopes and stamps in their

original position with a new adhesive. Young advised that this method had

only been carried out once on an envelope from 2002, and he did not rule out

damage resulting from the proposed testing.

The OAG opposed the OTSC with multiple certifications including one

from Gregory Ferrara, who stated the Museum regularly facilitates and

2 Plaintiff initially sought permission to test wood from a ladder allegedly related to the kidnapping but has abandoned that request on appeal. Thus, our decision does not address that issue.

A-1764-22 5 responds to requests for information from researchers, allowing access under

the direct supervision of museum archivists and implementing specific

precautions or conditions depending on the item being examined. Ferrara

certified that researchers are not permitted to expose Museum artifacts to

foreign chemicals or other substances, nor are they permitted to alter the

condition of the items. The OAG also submitted a certification from Michael

J. Kennedy, Jr., the Director of NJSP Office of Forensic Sciences, opining that

the DNA extraction tests proposed by plaintiff will permanently alter the

condition of each of the historical items tested and is potentially destructive to

the artifacts.

After the OAG opposed the OTSC, plaintiff submitted her own OPRA

requests to the OAG and NJSP on December 15, seeking the same DNA

testing as Braverman. 3 The OAG denied plaintiff's requests. Plaintiff did not

move for leave to file an amended verified complaint to seek relief related to

her OPRA requests.

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