State of New Jersey v. Hosea R. Jackson

CourtNew Jersey Superior Court Appellate Division
DecidedMay 27, 2025
DocketA-0736-23
StatusUnpublished

This text of State of New Jersey v. Hosea R. Jackson (State of New Jersey v. Hosea R. Jackson) 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
State of New Jersey v. Hosea R. Jackson, (N.J. Ct. App. 2025).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-0736-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

HOSEA R. JACKSON,

Defendant-Appellant. ________________________

Argued April 1, 2025 – Decided May 27, 2025

Before Judges Gilson, Firko, and Augostini.

On appeal from the Superior Court of New Jersey, Law Division, Atlantic County, Indictment No. 19-03-0571.

Rachel A. Neckes, Assistant Deputy Public Defender, argued the cause for appellant (Jennifer N. Sellitti, Public Defender, attorney; Rachel A. Neckes, of counsel and on the briefs).

Matthew T. Mills, Assistant Prosecutor, argued the cause for respondent (William E. Reynolds, Atlantic County Prosecutor, attorney; Matthew T. Mills, of counsel and on the brief).

PER CURIAM A jury convicted Hosea R. Jackson of third-degree criminal restraint,

N.J.S.A. 2C:13-2(a), and fourth-degree criminal sexual contact, N.J.S.A. 2C:14-

3(b). Thereafter, defendant was sentenced to three years of probation.

Defendant appeals from his convictions. Because the State should not have been

allowed to use defendant's statements to the police and because of other errors

at trial, we reverse his convictions and remand for further proceedings.

I.

The charges against defendant were based on allegations made by M.O.

(Mary), a housekeeper at a hotel in Atlantic City. 1 We discern the facts from

the record, including the testimony and evidence introduced at the Rule 104

hearing and at trial.

On July 30, 2018, Mary reported that defendant, who was staying at the

hotel, had sexually assaulted her in his room. Police officers Robert Reynolds

and George Mancuso responded to the hotel to investigate the incident. Their

interactions were captured on Reynolds' body-worn camera, which included

audio recordings.

1 We use initials and a fictitious name for the victim to protect her privacy interests. R. 1:38-3(c). A-0736-23 2 When they arrived at the hotel, the officers met with hotel security and

staff who brought them to Mary. Before interviewing Mary, a hotel security

officer informed the police officers that defendant was in the hallway outside

his room. The officers, accompanied by a hotel security officer, then went to

see defendant. As soon as they encountered defendant, the officers asked him

to take his hands out of his pockets and place his hands on his head. The officers

then frisked defendant and asked him for his name and identification. Defendant

invited the officers into his room and gave them his license.

The officers asked defendant a series of questions about what had

happened that morning and whether he had interacted with anybody from the

hotel. Defendant initially denied meeting anyone and explained that he was

staying at the hotel with his wife, who had gone to a seminar. Defendant also

stated that he had only gone out of his hotel room to smoke a cigarette.

While Mancuso stayed with defendant in his room, Reynolds went to

speak with Mary. Mary spoke Spanish, so another hotel employee translated the

questions asked by Reynolds and the answers given by Mary. Mary told the

officer that she had gone into defendant's room to deliver towels, defendant had

shut the door, and then he placed her hands over his genitals. Mary also stated

that defendant had told her "only five minutes." Reynolds asked Mary whether

A-0736-23 3 she wanted to file a criminal complaint against defendant and Mary agreed to go

to the police station to sign a complaint.

Reynolds then went back to question defendant further. Before re-

entering the room, Mancuso came out and Reynolds informed him of what Mary

said had happened. The officers agreed that based on Mary's statements,

defendant's actions constituted criminal restraint and criminal sexual contact.

When asked by a hotel security officer whether there were grounds to arrest

defendant, the officers responded with "yeah" and "absolutely."

Reynolds and Mancuso then re-entered defendant's room and questioned

him further about what happened. Over the next three-and-a-half minutes,

defendant was asked numerous questions concerning what happened in his hotel

room and whether he had any interactions with hotel staff.

Defendant initially denied having any issues with anyone from the hotel.

When asked by one of the officers whether he was "sure that nothing happened

between [him] and anybody in [his hotel] room," defendant replied that he was

"[v]ery positive." Shortly thereafter, however, defendant acknowledged that a

housekeeper had come into his room to deliver towels. When asked about his

interactions with the housekeeper, defendant denied that he had touched the

housekeeper or that his door had been shut. Finally, defendant was asked if he

A-0736-23 4 had anything else to tell the officers. Defendant responded no. The officers

then informed defendant that he was under arrest and placed him in handcuffs.

Later that day, Mary went to the police station and provided further details

to the investigating officers. She also prepared a written statement. Thereafter,

defendant was indicted and charged with fourth-degree criminal sexual contact

and third-degree criminal restraint.

Just before the beginning of trial, the State moved to admit the statements

defendant had given to Reynolds and Mancuso. The trial court conducted a Rule

104 hearing outside the presence of the jury. The trial court did not hear any

testimony at the Rule 104 hearing; instead, the court reviewed briefs and heard

arguments from counsel. The trial court then granted the State's motion,

explaining its reasons on the record.

The trial court never addressed the issue of whether defendant was in

custody. Rather, the court reasoned that the officers had asked defendant "some

preliminary questions," which the trial court characterized as "initial

investigatory questions." The trial court then ruled that the State could use

defendant's statements and introduce the portion of the footage from the police

body-worn camera up to the point just before defendant was arrested.

A-0736-23 5 The matter then proceeded to trial. At trial, the State called three

witnesses: Reynolds, Mancuso, and Mary. Mary testified through a Spanish

interpreter. The State also introduced and played for the jury a redacted portion

of the footage from Reynolds' body-worn camera. The footage included the

police's initial encounter with and questioning of defendant, and the questioning

that occurred after Reynolds had spoken with Mary.

At trial, Mary testified that she had dropped off towels in Room 1402 ,

where defendant was staying. She stated that while in the room, defendant

closed the door behind her and refused to let her leave. Mary went on to testify

that defendant grabbed one of her hands and placed it on his genitals. Mary

recalled that defendant "kept telling [her to] just lay in the bed for five minutes"

and "get undressed." Mary explained that she pretended to comply with

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