State of New Jersey v. Humphrey Cohen

CourtNew Jersey Superior Court Appellate Division
DecidedJune 17, 2025
DocketA-1558-23
StatusUnpublished

This text of State of New Jersey v. Humphrey Cohen (State of New Jersey v. Humphrey Cohen) 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. Humphrey Cohen, (N.J. Ct. App. 2025).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-1558-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

HUMPHREY COHEN,

Defendant-Appellant. ________________________

Submitted April 1, 2025 – Decided June 17, 2025

Before Judges Susswein and Bergman.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Indictment No. 83-03-1433.

Humphrey Cohen, appellant pro se.

Theodore N. Stephens, II, Essex County Prosecutor, attorney for respondent (Matthew E. Hanley, Assistant Prosecutor, of counsel and on the brief).

PER CURIAM

Defendant Humphrey Cohen appeals from a trial court order denying his

petition for post-conviction relief (PCR) without a hearing. He asserts the instructions provided to the jury were improper and the PCR court committed

error in denying his application as untimely. We disagree and affirm.

I.

We briefly reiterate the underlying facts and procedural history taken from

our opinion in defendant's most recent appeal. State v. Cohen, No. A-1890-22

(App. Div. Mar. 27, 2024) (slip op. at 1-3) (Cohen IV). On January 26, 1983,

defendant and his co-defendants confronted Otha Thompson as he crossed the

street. Defendant kicked Thompson, knocked him to the ground, and fired a

bullet into his chest. Defendant shot Thompson a second time and he and his

accomplices took Thompson's wallet before fleeing. They later divided up the

money from Thompson's wallet. Thompson was subsequently taken to a

hospital where he was pronounced dead. Defendant was arrested and confessed

to shooting Thompson during the robbery.

Defendant was found guilty of felony murder, N.J.S.A. 2C:11-3(a)(3)

(count one); purposeful and knowing murder, N.J.S.A. 2C:11-3(a)(1)(2) (count

two); first-degree robbery, N.J.S.A. 2C:15-1(count three); and unlawful

possession of a weapon, N.J.S.A. 2C:39-5(b) (count four). State v. Cohen, 211

N.J. Super. 544, 547 (App. Div. 1986) (Cohen I). Defendant was sentenced to

life imprisonment with thirty years of parole ineligibility on count two and

A-1558-23 2 fifteen years with seven years and six months of parole ineligibility on count

three. Ibid. The sentences were to run consecutively for an aggregate sentence

of life in prison with thirty-seven years and six months of parole ineligibility.

Ibid. The felony murder charge was merged with the purposeful and knowing

murder charge for sentencing purposes. Ibid. Defendant's conviction for

unlawful possession of a weapon was merged with his first-degree robbery

conviction. Ibid.

We affirmed defendant's sentence and conviction on direct appeal. Id. at

554. After his convictions, defendant filed eight PCR petitions, all of which

were denied by the trial court and affirmed on appeal. The Supreme Court

denied certification as to all eight petitions. Defendant petitioned the Supreme

Court of the United States for a writ of certiorari as to one of his petitions, which

the Court denied. Cohen v. New Jersey, 565 U.S. 1238 (2012).

We also affirmed the denials of three motions to correct an illegal sentence

filed by defendant. State v. Cohen, No. A-2599-16 (App. Div. Mar. 9, 2018)

(slip op. at 3) (Cohen II); State v. Cohen, No. A-0832-19 (App. Div. Feb. 4,

2021) (slip op. at 1) (Cohen III); and Cohen IV, (slip op. at 1). Defendant's

federal habeas corpus petition was also denied. Cohen v. Morton, No. 94-3257,

2014 U.S. Dist. LEXIS 56149 (D.N.J. Apr. 17, 2014).

A-1558-23 3 This appeal concerns the denial of defendant's ninth PCR petition in

December 2024. The trial court's order found "[defendant's] request for

construction and relaxation of New Jersey Court [Rules] 3:22-4; 3:22-5; and

3:22-12; pursuant to [Rule] 1:1-2 is hereby DENIED []" and "[d]efendant's

challenge[s] to his 1984 convictions were fully litigated during [] defendant's

previous appeals and eight post-conviction relief applications." The PCR court

also adopted and incorporated the prior trial court's decision denying defendant's

third motion to correct an illegal sentence in December 2022 which we

subsequently affirmed in Cohen IV.

Defendant appeals the PCR court's order asserting:

POINT I THE POST CONVICTION RELIEF COURT COMMITTED ERROR WHEN IT DID NOT ADDRESS APPELLANT'S CLAIM THAT THE PROCEDURAL BARS MUST BE LIFTED TO DETERMINE WHETHER HIS CLAIMS HAVE MERIT IN SHOWING THAT A SERIOUS, PERVASIVE DEFECT EXISTS IN THE JURY CHARGE.

POINT II THE PCR COURT DID NOT ADDRESS THE MERIT OF APPELLANT'S ARGUMENT WHICH SHOWS, THOUGH COUNSEL HAD PRESENTED TWO DIFFERENT DEFENSES TO JUSTIFY THE MURDER OFFENSE BEING REDUCED TO EITHER AGGRAVATED MANSLAUGHTER OR MANSLAUGHTER, BOTH DEFENSES WERE

A-1558-23 4 UNDERMINED WHEN THE JURY RECEIVED DEFECTIVE INSTRUCTIONS WHEN IT WAS NOT TOLD: IT IS THE BURDEN OF THE STATE TO PROVE BEYOND A REASONABLE DOUBT DEFENDANT'S DEFENSE[S] DOES NOT WARRANT THE MURDER OFFENSE BEING REDUCED TO EITHER AGGRAVATED MANSLAUGHTER OR MANSLAUGHTER.

POINT III THE PCR COURT DID NOT ADDRESS THE MERIT OF APPELLANT'S ARGUMENT WHICH SHOWS, THOUGH APPELLANT HAD PRESENTED A DEFENSE OF VOLUNTARY INTOXICATION TO JUSTIFY THE MURDER OFFENSE BEING REDUCED TO EITHER AGGRAVATED MANSLAUGHTER OR MANSLAUGHTER, THE JURY RECEIVED DEFECTIVE INSTRUCTIONS WHEN IT WAS NOT INSTRUCTED THAT IT IS THE BURDEN OF THE STATE TO PROVE BEYOND A REASONABLE DOUBT DEFENDANT'S EVIDENCE OF VOLUNTARY INTOXICATION DOES NOT WARRANT THE MURDER OFFENSE BEING REDUCED TO EITHER AGGRAVATED MANSLAUGHTER OR MANSLAUGHTER.

POINT IV THE PCR COURT DID NOT ADDRESS APPELLANT'S CLAIM THAT HIS STATE AND U.S CONSTITUTIONAL RIGHTS TO PRESENT A DEFENSE TO REDUCE/MITIGATE FELONY MURDER TO MANSLAUGHTER WERE VIOLATED DUE TO THE ABSENCE OF A JURY CHARGE TO CONVEY TO THE JURY THAT EVIDENCE OF VOLUNTARY INTOXICATION HAS BEEN INTRODUCED BY DEFENDANT TO ACQUIT HIM OF ROBBERY FOR THE PURPOSE

A-1558-23 5 OF REDUCING FELONY MURDER TO MANSLAUGHTER.

II.

As the PCR court did not hold an evidentiary hearing on the claims

defendant now raises on appeal, we "conduct a de novo review." State v. Harris,

181 N.J. 391, 421 (2004). The time limits of Rule 3:22-12(a)(2) with regard to

a petition for post-conviction relief cannot be relaxed by invoking Rule 1:1-2 or

Rule 3:22-12(a)(1), because our Supreme Court in 2009 and 2010 amended Rule

1:3-4, Rule 3:22-4(b), and Rule 3:22-12 to preclude enlargement or relaxation.

State v. Jackson, 454 N.J. Super. 284, 287 (App. Div. 2018).

Rule 3:22-4(b) states in relevant part that "[a] second or subsequent

petition for post-conviction relief shall be dismissed unless: it is timely under

Rule 3:22-12(a)(2).

Rule 3:22-12(a)(2) provides:

Notwithstanding any other provision in this rule, no second or subsequent petition shall be filed more than one year after the latest of:

(A) the date on which the constitutional right asserted was initially recognized by the United States Supreme Court or the Supreme Court of New Jersey, if that right has been newly recognized by either of those Courts and made retroactive by either of those Courts to cases on collateral review; or

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Harris
859 A.2d 364 (Supreme Court of New Jersey, 2004)
State v. Cohen
512 A.2d 500 (New Jersey Superior Court App Division, 1986)
State v. Warren
518 A.2d 218 (Supreme Court of New Jersey, 1986)
State v. Jackson
185 A.3d 262 (New Jersey Superior Court App Division, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
State of New Jersey v. Humphrey Cohen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-humphrey-cohen-njsuperctappdiv-2025.