State of New Jersey v. Erick Marti

New Jersey Superior Court Appellate Division·Decided March 20, 2026·No. A-4089-23·Unpublished

Opinion

RECORD IMPOUNDED

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-4089-23

STATE OF NEW JERSEY, Plaintiff-Respondent,

v.

ERICK MARTI, a/k/a ERIC RODRIGUEZ, ERIK RODRIGUEZ, JOSE RODRIGUEZ, ERIC MARTI, and ENRICK MARTI,

Defendant-Appellant.

Submitted October 29, 2025 – Decided March 20, 2026 Before Judges Gummer and Vanek.

On appeal from the Superior Court of New Jersey, Law Division, Cumberland County, Indictment No. 16-04-

0341.

Jennifer N. Sellitti, Public Defender, attorney for appellant (John V. Molitor, Designated Counsel, on the brief).

Jennifer Webb-McRae, Cumberland County Prosecutor, attorney for respondent (Kimberly P. Will, Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant Erick Marti appeals from an order denying his petition for post-conviction relief (PCR), which the court entered after hearing argument but without conducting an evidentiary hearing. Defendant claims his plea counsel rendered ineffective assistance by failing to investigate defenses of diminished capacity and intoxication. Perceiving no error in the PCR court's finding that defendant did not establish a prima facie case of ineffective assistance of counsel and no abuse of discretion in the court's decision to forgo an evidentiary hearing, we affirm.

Defendant was arrested following an attack that occurred on a New Jersey Transit bus on September 6, 2015. A grand jury subsequently returned an indictment charging defendant with first-degree attempted murder, N.J.S.A. 2C:5-1(a)(3) and N.J.S.A. 2C:11-3; first-degree aggravated sexual assault, N.J.S.A. 2C:14-2(a)(6); second-degree aggravated assault, N.J.S.A. 2C:12- 1(b)(1); third-degree terroristic threats, N.J.S.A. 2C:12-3(a); third-degree criminal restraint, N.J.S.A. 2C:13-2(a); and third-degree aggravated criminal sexual contact, N.J.S.A. 2C:14-3(a).

Pursuant to a negotiated plea agreement, defendant entered a guilty plea to first-degree attempted murder and first-degree aggravated sexual assault. In

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the plea agreement, the State agreed to recommend defendant receive concurrent fifteen-year imprisonment terms, subject to an eighty-five-percent parole- ineligibility period pursuant to the No Early Release Act, N.J.S.A. 2C:43-7.2. In response to questions from the trial court, defendant testified during the plea hearing he had reviewed the plea form with plea counsel, had signed it, did not have any questions about the plea, and was satisfied with plea counsel's services. As to the charges, defendant admitted he had put his hands around the victim's neck, had attempted to strangle her, and had inserted his finger into her anus while she was unconscious. He testified he had "used some type of drugs" before the attack but was aware of what he was doing at the time of the attack.

As memorialized in a January 14, 2019 judgment of conviction, the court later sentenced defendant in accordance with the plea agreement. Defendant did not appeal the convictions or sentence.

In 2023, defendant, representing himself, moved for "Performance of Forensic DNA Testing," citing N.J.S.A. 2A:84A-32A. The court treated the motion as a PCR petition under Rule 3:22 and assigned counsel. In a brief, PCR counsel argued plea counsel had rendered ineffective assistance by failing "to investigate, engage, or . . . consult a DNA expert" or to raise a diminished- capacity defense, claiming that at the time of the attack defendant "was beside

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himself under the influence of an unknown substance, most likely PCP and that he was not capable of forming the requisite intent to commit the [charged] offenses . . . ."

In support of the petition, defendant submitted a certification "address[ing] issues of ineffective assistance of counsel that put [him] in a position [of] having to plead guilty to aggravated sexual assault." Defendant admitted he had "physically assaulted the victim" and "nearly killed her" but, contrary to the testimony he had given during the plea hearing, denied he had penetrated or sexually assaulted her. He claimed that before the attack, "without [his] knowledge, [he] was given PCP that caused [him] to become angry and aggressive." He stated he "barely remember[ed] getting on the bus" and had "no memory of saying the things the witnesses claim[ed] [he] said," but he knew he "was confused and disoriented."

In the certification, defendant asserted plea counsel had told him "he would not prepare a defense for [him] and would . . . do nothing but attend the status conferences and attempt to negotiate a [plea] deal . . . for [him]." He stated he had asked plea counsel "about a mental health evaluation and possibly presenting a diminished capacity defense" and that plea counsel had "told [him] it was too soon to worry about that because almost all of his cases resulted in

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plea bargains." He claimed he "suffer[ed] from ____________," a condition that "was compounded by [his] unwitting ingestion of PCP," but defendant did not fill in the blank or otherwise identify the condition he allegedly had. He stated he "believe[d] [he] had a viable diminished capacity defense and that [his] overall plea bargain and sentence would have been more favorable if [his] lawyer had bothered to assist [him] to develop that defense." He asserted he "came to believe that [he] had no choice but to plead guilty to protect [him]self from the negative consequences [he] was facing if [he] was convicted after a jury trial."

Defendant attached to his certification a September 6, 2015 hospital record, which indicated defendant had been admitted to the hospital at 9:18 p.m. after police officers brought him to the hospital "for medical clearance and crisis eval[uation] for suicidal thoughts." The record described defendant as "present[ing] to the emergency department with homicidal ideation, psychosis, . . ." and as being "acutely psychotic." It identified a prior diagnosis of "manic behavior," prior symptoms of "homicidal ideation[] [and] suicide ideation," and previous "PCP abuse." Defendant was discharged within nine hours of his admission. The ultimate diagnosis was "Substance Induced Mood Disorder; Cocaine Abuse; Hallucinogen intoxication; [and] cannabis abuse."

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The PCR record also contained an October 22, 2018 evaluation of defendant prepared by psychologist Jesse Wolpert pursuant to N.J.S.A. 2C:47- 1 to -2. Dr. Wolpert described the reasons defendant had given him in an effort to explain "why his behavior was justified and why he was not responsible for his actions." According to Dr. Wolpert, defendant "blamed his behavior on a friend who gave him a cigarette without telling him it was laced with PCP, implying that the effects of the PCP caused him to lose control." Dr. Wolpert noted defendant "could not come up with a reasonable explanation why he had such an extreme reaction to PCP when he admitted using it before and he didn't become violent." Defendant "denied experiencing hallucinations," and Dr. Wolpert found "no evidence of loose associations or delusions, to suggest the presence of a psychotic thought disorder." Dr. Wolpert concluded defendant's "behavior during the present offense is likely due in part to antisocial personality traits and a criminal mindset that permits him to justify the extreme use of violence, callously disregard the impact of his behavior on others, and avoid taking any responsibility for his actions."

At oral argument, PCR counsel advised the PCR court defendant was withdrawing his DNA-based argument and was relying only on his contention plea counsel "should have had [defendant] evaluated for some cognitive deficit,

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