State of New Jersey v. Jamal E. Gadson

CourtNew Jersey Superior Court Appellate Division
DecidedAugust 6, 2025
DocketA-2156-23
StatusUnpublished

This text of State of New Jersey v. Jamal E. Gadson (State of New Jersey v. Jamal E. Gadson) 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. Jamal E. Gadson, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2156-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

JAMAL E. GADSON, a/k/a JAMAL GADSON, JAMAL E. DADSON, JAMAL EMMETT GADSON, and GEEZY,

Defendant-Appellant. ___________________________

Submitted May 21, 2025 – Decided August 6, 2025

Before Judges DeAlmeida and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Camden County, Indictment No. 17-05-1212 and Accusation No. 17-09-2538.

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

Grace C. MacAulay, Camden County Prosecutor, attorney for respondent (Kevin J. Hein, Assistant Prosecutor, of counsel and on the brief). PER CURIAM

Defendant Jamal E. Gadson appeals from the February 7, 2024 order

denying his petition for post-conviction relief (PCR) without an evidentiary

hearing. We affirm.

On September 20, 2017, defendant pleaded guilty to Accusation No. 17-

09-2538, first-degree armed robbery, N.J.S.A. 2C:15-1(a)(1); and count two of

Indictment No. 17-05-1212, third-degree possession of a controlled dangerous

substance (CDS) with intent to distribute, N.J.S.A. 2C:35-5(b)(3). In exchange

for defendant's guilty plea, the State agreed to dismiss the remaining counts of

the indictment and recommend an eighteen-year sentence for the armed robbery

and a concurrent four-year sentence for the CDS offense, both sentences to run

concurrently with a pending violation of probation.

Because the armed robbery conviction was subject to the No Early Release

Act, N.J.S.A. 2C:43-7.2, the court advised defendant the eighty-five percent

mandatory period of parole ineligibility on an eighteen-year sentence was fifteen

years, three months and eighteen days. Prior to accepting the plea, the court

conducted a colloquy with defendant to ensure he knowingly and voluntarily

entered into the agreement. Defendant then provided a factual basis for the

armed robbery charge, admitting he was armed with a knife and used force to

A-2156-23 2 take a purse from a person; and for the CDS offense, admitting he possessed

heroin intending to sell it.

At the commencement of the October 13, 2017 sentencing hearing, the

assistant prosecutor advised the court the "matters were the subject of the

negotiated agreement," and moved for sentencing in accordance with the plea

agreement. The court confirmed with defense counsel there were no changes or

modifications to the presentence report and then reviewed the appeal rights form

with defendant. The court did not ask defense counsel if he wanted to be heard,

nor did counsel request to be heard, as to sentencing. Defendant declined to

make a statement before the court imposed sentence.

Pursuant to N.J.S.A. 2C:44-1(a), the court found aggravating factors three

(the risk that the defendant will commit another offense), six (the extent of the

defendant's prior criminal record and the seriousness of the offenses of which

the defendant has been convicted), and nine (the need for deterring the defendant

and others from violating the law), which it determined clearly and substantially

outweighed the non-existent mitigating factors. Finding the plea agreement fair

and in the interests of justice, the court imposed the recommended sentence in

accordance with the plea agreement. We considered defendant's appeal on the

sentencing oral argument calendar and affirmed on February 13, 2019.

A-2156-23 3 On January 12, 2023, defendant filed a petition for PCR alleging

ineffective assistance of counsel in preparation for and during the sentencing

hearing. Assigned counsel filed an amended petition.

After considering argument, the PCR court denied the petition without an

evidentiary hearing. In its February 7, 2024 oral decision, the court found

defendant failed to meet either prong of Strickland v. Washington, 466 U.S. 668

(1984). First, the court determined defense counsel's representation at

sentencing did not fall below an objective standard of reasonableness because,

although counsel had a right to argue for a lesser sentence under State v. Warren,

115 N.J. 433 (1989), he was not obligated to do so. In addition, the court found

defendant could not demonstrate that, had counsel argued for a lesser term, the

court would have imposed a lesser sentence.

On appeal, defendant argues:

THIS COURT SHOULD REVERSE THE PCR COURT'S DECISION TO DENY THE DEFENDANT'S REQUEST FOR AN EVIDENTIARY HEARING ON THE ISSUE OF WHETHER THE DEFENDANT'S ATTORNEY SHOULD HAVE ARGUED FOR A LESSER SENTENCE.

To succeed on a claim of ineffective assistance of counsel, a defendant

must establish by a preponderance of the evidence both prongs of the test set

forth in Strickland, 466 U.S. at 687, and adopted by our Supreme Court in State

A-2156-23 4 v. Fritz, 105 N.J. 42, 58 (1987). State v. Gaitan, 209 N.J. 339, 350 (2012). First,

a "defendant must show that counsel's performance was deficient." Strickland,

466 U.S. at 687. A defendant must demonstrate "counsel made errors so serious

that counsel was not functioning as the 'counsel' guaranteed the defendant by the

Sixth Amendment." Ibid. The Constitution requires "reasonably effective

assistance," so an attorney's performance may not be attacked unless it was not

"within the range of competence demanded of attorneys in criminal cases" and

instead "fell below an objective standard of reasonableness." Id. at 687-88.

When assessing the first Strickland prong, "[j]udicial scrutiny of counsel's

performance must be highly deferential," and "every effort [must] be made to

eliminate the distorting effects of hindsight." Id. at 689. A reviewing court

"must indulge a strong presumption that counsel's conduct falls within the wide

range of reasonable professional assistance," and "the defendant must overcome

the presumption that, under the circumstances, the challenged action [by

counsel] 'might be considered sound trial strategy.'" Strickland, 466 U.S. at 689

(quoting Michel v. Louisiana, 350 U.S. 91, 101 (1955)).

Under the second Strickland prong, a defendant must "affirmatively

prove" "a reasonable probability that, but for counsel's unprofessional errors,

the result of the proceeding would have been different." State v. Gideon, 244

A-2156-23 5 N.J. 538, 551 (2021) (quoting Strickland, 466 U.S. at 693-94). "A reasonable

probability is a probability sufficient to undermine confidence in the outcome."

Ibid. (quoting Strickland, 466 U.S. at 694).

Because the PCR court denied the petition without an evidentiary hearing,

we review the order de novo. State v. Harris, 181 N.J. 391, 421 (2004). We

review the decision to deny the petition without an evidentiary hearing for abuse

of discretion. State v. Preciose, 129 N.J. 451, 462 (1992).

Although defense counsel has "an unfettered right to argue in favor of a

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Related

Michel v. Louisiana
350 U.S. 91 (Supreme Court, 1956)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Cummings
728 A.2d 307 (New Jersey Superior Court App Division, 1999)
State v. Briggs
793 A.2d 882 (New Jersey Superior Court App Division, 2002)
State v. Sainz
526 A.2d 1015 (Supreme Court of New Jersey, 1987)
State v. Harris
859 A.2d 364 (Supreme Court of New Jersey, 2004)
State v. Fritz
519 A.2d 336 (Supreme Court of New Jersey, 1987)
Fischer v. Township of Bedminster
76 A.2d 673 (Supreme Court of New Jersey, 1950)
State v. Warren
558 A.2d 1312 (Supreme Court of New Jersey, 1989)
State v. Preciose
609 A.2d 1280 (Supreme Court of New Jersey, 1992)
State v. Hess
23 A.3d 373 (Supreme Court of New Jersey, 2011)
State v. S.C.
672 A.2d 1264 (New Jersey Superior Court App Division, 1996)

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State of New Jersey v. Jamal E. Gadson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-jamal-e-gadson-njsuperctappdiv-2025.