State of New Jersey v. Hampton J. Lee

New Jersey Superior Court Appellate Division·Decided August 4, 2026·No. A-3334-23·Unpublished

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3334-23

STATE OF NEW JERSEY, Plaintiff-Respondent,

v.

HAMPTON J. LEE, a/k/a LEE HAMPTON,

Defendant-Appellant.

Submitted May 21, 2026 – Decided August 4, 2026 Before Judges Mawla and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Camden County, Indictment No. 22-11-3409.

Jennifer N. Sellitti, Public Defender, attorney for appellant (Amira R. Scurato, Designated Counsel, on the brief).

Grace C. MacAulay, Camden County Prosecutor, attorney for respondent (Rachel M. Lamb, Assistant Prosecutor, of counsel and on the brief).

PER CURIAM

Following a jury trial, defendant Hampton J. Lee appeals from a March 8, 2024 judgment of conviction finding him guilty of second-degree aggravated assault and imposing a seven-year prison term. We affirm the conviction but remand for resentencing.

I.

Trial testimony established the following. In 2021, Lawrence King was living with his girlfriend Stephanie Walker in Camden. Late one December evening, Walker awoke to a telephone call between King and defendant, whom she previously dated. The men were arguing because King was offended by text messages defendant sent Walker. King was "aggressive" during the phone exchange, calling defendant a derogatory name and discussing prior sexual acts between defendant and Walker.

Shortly after the call ended, defendant arrived unannounced in front of Walker's residence. Upon learning defendant was outside, Walker told King to remain inside, but King "snuck" out the back door with the intent to "square up" with defendant. Walker exited less than a minute later and found King lying unconscious on the ground. Walker saw defendant kick King and then leave the scene in a truck with another male.

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King was subsequently transported to the hospital, where he was intubated and remained unresponsive. He had sustained blunt trauma to his face, an intracranial hemorrhage, and fractures to the bones of his right eye socket. These injuries were considered life threatening and required surgical intervention. King remained hospitalized for approximately five months, then underwent inpatient and outpatient rehabilitation. As a result of his injuries, King was unable to walk without assistance.

In November 2022, a Camden County grand jury returned an indictment charging defendant with second-degree aggravated assault, N.J.S.A. 2C:12- 1(b)(1). Defendant's jury trial commenced in October 2023.

During the charge conference, which was conducted prior to the close of testimony, defendant asked the court to charge disorderly persons simple assault as a lesser-included offense of second-degree aggravated assault. The court denied the request, opining no reasonable jury could find simple assault because the incident resulted in "serious bodily injury," rather than the "bodily injury" required for simple assault. After the close of evidence, the court reiterated its decision in this regard. The resulting verdict sheet did not list the degree of offense but required the jury to decide whether there was serious bodily injury,

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which would result in a second-degree conviction, or significant bodily injury, which would result in a third-degree conviction.

The court also denied defendant's motion for a judgment of acquittal, finding the evidence was sufficient to warrant a conviction of the charge. The jury then returned a guilty verdict for second-degree aggravated assault based on serious bodily injury.

Defendant subsequently moved for a new trial and judgment of acquittal, styled as a motion to vacate the verdict. He contended the State failed to disprove self-defense and, for the first time, argued the court erred by not charging the lesser-included offense of simple assault by mutual combat.

After considering argument, the court denied both motions. It determined there was sufficient evidence for a reasonable jury to find guilt beyond a reasonable doubt, and the State had disproved self-defense. In rejecting defendant's argument for a lesser-included charge of mutual combat, the court found no rational basis for the charge, reasoning as follows:

[T]he simple assault [charge] was not necessary because I . . . don't find . . . it would be possible to . . .

acquit . . . defendant of aggravated assault, and then find he was guilty of simple assault based on the nature of the injuries . . . , which I will classify as horrific.

So, essentially, from a legal point of view . . . I'm assuming the defense is arguing that the mutual

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[combat] to be a lesser-included offense. I don't find that that is the case under aggravated assault . . . .

There's no mutual [combat] under the aggravated assault section of the statute. And [N.J.S.A.] 2C:1-

8[(e)] provides that the [c]ourt shall not charge the jury with respect to a[n] included offense, unless there's a rational basis for a verdict convicting . . . defendant of the included offense. So . . . there wasn't a rational basis based on that.

In my opinion, I gave . . . defendant the benefit of having the lesser-included charge of the third-degree significant assault. And it was the fact finders' call of the jury and they have spoken. I don't feel any reason for me to change that . . . . So that part also is denied.

During the sentencing hearing, the court found the following aggravating factors: three ("[t]he risk that the defendant will commit another offense"), N.J.S.A. 2C:44-1(a)(3); six ("[t]he extent of the defendant's prior criminal record and the seriousness of the offenses of which the defendant has been convicted"), N.J.S.A. 2C:44-1(a)(6); and nine ("[t]he need for deterring the defendant and others from violating the law"), N.J.S.A. 2C:44-1(a)(9). The court found the following mitigating factors: two ("[t]he defendant did not contemplate that the defendant's conduct would cause or threaten serious harm"), N.J.S.A. 2C:44-1(b)(2); five ("[t]he victim of the defendant's conduct induced or facilitated its commission"), N.J.S.A. 2C:44-1(b)(5); and eleven ("[t]he imprisonment of the defendant would entail excessive hardship to the

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defendant or the defendant's dependents"), N.J.S.A. 2C:44-1(b)(11). After determining "the aggravating factors clearly, convincingly[,] and substantially outweigh[ed] the mitigating factors," the court sentenced defendant to a seven- year prison term, subject to the No Early Release Act, N.J.S.A. 2C:43-7.2.

On appeal, defendant raises the following issues for our consideration:

POINT I

THE TRIAL JUDGE ERRED IN FAILING TO CHARGE THE DISORDERLY PERSONS OFFENSE OF SIMPLE ASSAULT AND THE PETTY DISORDERLY PERSONS OFFENSE OF MUTUAL CONSENT.

POINT II

SELF-DEFENSE WAS NOT DISPROVED UNANIMOUSLY BY THE STATE. FURTHER, THE JUDGE FAILED TO TAILOR THE SELF[-]

DEFENSE CHARGE TO THE FACTS AND A REVERSAL IS REQUIRED.

POINT III

DEFENDANT'S SENTENCE WAS EXCESSIVE AND SHOULD BE REDUCED.

II.

A.

Addressing these contentions in turn, we first consider defendant's challenges to the jury instructions. It is well established that "[a]ppropriate and A-3334-23

proper charges to a jury are essential for a fair trial." State v. Carrero, 229 N.J. 118, 127 (2017) (quoting State v. Daniels, 224 N.J. 168, 180 (2016)). If a defendant challenges the instruction before the trial court, "[e]rroneous instructions are poor candidates for rehabilitation as harmless, and are ordinarily presumed to be reversible error." State v. McKinney, 223 N.J. 475, 495-96 (2015) (alteration in original) (quoting State v. Afanador, 151 N.J. 41, 54 (1997)).

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