State of New Jersey v. James A. Michaud

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 30, 2026
DocketA-1321-24
StatusUnpublished

This text of State of New Jersey v. James A. Michaud (State of New Jersey v. James A. Michaud) 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. James A. Michaud, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-1321-24

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

JAMES A. MICHAUD,

Defendant-Appellant. ________________________

Submitted January 21, 2026 – Decided January 30, 2026

Before Judges Sumners and Chase.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Indictment No. 23-12-1482.

Jennifer N. Sellitti, Public Defender, attorney for appellant (Zachary G. Markarian, Assistant Deputy Public Defender, of counsel and on the brief).

Wayne Mello, Acting Hudson County Prosecutor, attorney for respondent (Penelope Mary Way, Special Deputy Attorney General/Acting Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant James Michaud appeals from his conviction, and challenges an

October 31, 2024 order denying his motion to dismiss a one-count indictment

for failure to notify, N.J.S.A. 2C:7-2d(1). We affirm.

I.

The facts pertinent to defendant's motion are summarized from the grand

jury proceeding, during which the State presented testimony from one witness ,

Secaucus Police Department Detective Kristen Bronowich.

Detective Bronowich testified that on August 22, 2023, Detective Sean

Egan of the Secaucus Police Department received a report from Integrity House

that on August 2, 2023, defendant had left their recovery program where he had

been residing. Detective Bronowich further explained that due to a 1999

conviction, defendant was subject to Megan's Law registration requirements.

Lastly, she testified that defendant had failed to properly notify law enforcement

of his whereabouts and did not re-register, as required, by Megan's Law.

After the prosecutor concluded questioning Bronowich, a grand juror

asked her if defendant had not checked in or registered since August 2, 2023,

and she replied:

So, the defendant in this matter is a registered sex offender and he was living in Secaucus at the Integrity House. Based on the law, you're supposed to notify us within ten days of you leaving so we can clear you from

A-1321-24 2 our system and you could re-register in your new facility. He failed to do that. He left prior to letting us know. He absconded from Integrity House; therefore, he did not notify us within the proper amount of time. So, we had no idea he left and he was supposed to re- register.

The grand jury returned the single-count indictment against defendant.

Relying on State v. Vasky, 218 N.J. Super. 487, 491 (App. Div. 1987),

defendant moved to dismiss the indictment. Defendant argued the indictment

was based on hearsay and that Detective Bronowich lacked personal knowledge.

After considering the written submissions and arguments of counsel, the motion

judge denied defendant's motion to dismiss the indictment. The judge reasoned

that:

The charge [d]efendant was indicted for in this case is readily distinguishable from the third-degree theft charge that Vasky remanded for further findings. In this case, Det. Bronowich presented evidence to the grand jury as to each and every element of the charged offense. Also, Det. Egan who investigated the underlying offense had personal knowledge as to all the necessary elements. In Vasky, neither the witness who testified before the grand jury nor the "inspectors" who reported it had personal knowledge of the value of the stolen fixtures. Therefore, unlike the circumstances of Vasky, this [c]ourt finds that the statements made by Det. Bronowich before the grand jury were either based on personal knowledge or supported by personal knowledge.

A-1321-24 3 The judge then determined the State's use of hearsay testimony and other

evidence, which may be inadmissible at trial, did not warrant dismissal of the

indictment. The judge also found Detective Bronowich's testimony did not

subvert the function of the grand jury.

After denial of his motion to dismiss the indictment, defendant entered a

guilty plea and was sentenced to time served. Defendant expressly reserved his

right to appeal the denial of his motion.

In his sole argument on appeal, defendant contends:

THE INDICTMENT MUST BE DISMISSED BECAUSE THE STATE DID NOT ESTABLISH THAT ANY PERSON HAD PERSONAL KNOWLEDGE OF THE FACTS FORMING THE BASIS FOR THE CHARGE.

II.

We review a trial court's denial of a motion to dismiss an indictment for

abuse of discretion. State v. Bell, 241 N.J. 552, 561 (2020) (quoting State v.

Twiggs, 233 N.J. 513, 44 (2018)). We will find an abuse of discretion only

where a "'decision is made without a rational explanation, inexplicably departed

from established policies, or rested on an impermissible basis.'" State v. Reyes-

Rodriguez, 480 N.J. Super. 526, 548 (App. Div. 2025) (quoting State v. Chavies,

247 N.J. 245, 257 (2021)). "[A] functional approach to abuse of discretion

A-1321-24 4 examines whether there are good reasons for an appellate court to defer to the

particular decision at issue." State v. R.Y., 242 N.J. 48, 65 (2020) (quoting

Flagg v. Essex Cnty. Prosecutor, 171 N.J. 561, 571 (2002)). When a trial court's

decision turns on a legal question, we review that determination de novo,

without deference to the trial court's interpretation. Twiggs, 233 N.J. at 532.

III.

Under Article I, Paragraph 8 of the New Jersey Constitution "[n]o person

shall be held to answer for a criminal offense, unless on the presentment or

indictment of a grand jury." The grand jury "operates as both a sword and

shield[,]" State v. Shaw, 241 N.J. 223, 235 (2020), by "bring[ing] to trial those

who are probably guilty" and "clear[ing] the innocent of baseless charges," In re

Grand Jury Appearance Request by Loigman, 183 N.J. 133, 138 (2005). To that

end, grand juries "serve a dual purpose: to determine if probable cause exists

and to stand between the defendant and the power of the State and protect

defendants from unfounded prosecutions." Shaw, 241 N.J. at 238 (internal

quotation marks omitted). Accordingly, "[t]he grand jury has always occupied

a high place as an instrument of justice in our system of criminal law. . . ." State

v. Del Fino, 100 N.J. 154, 165 (1985).

A-1321-24 5 To issue an indictment, a grand jury must be presented with sufficient

evidence, viewed in the light most favorable to the State, establishing a prima

facie case as to each crime. State v. Hogan, 144 N.J. 216, 227 (1996). In

establishing a prima facie case, "the State may not deceive the grand jury or

present its evidence in a way that is tantamount to telling the grand jury a 'half-

truth.'" Id. at 236.

"Once a grand jury returns an indictment, a court should dismiss that

indictment 'only on the clearest and plainest ground, and only when the

indictment is manifestly deficient or palpably defective.'" Bell, 241 N.J. at 560

(quoting Twiggs, 233 N.J. at 531-32). Dismissal of an indictment is a "last resort

because the public interest, the rights of victims and the integrity of the criminal

justice system are at stake." State v. Williams, 441 N.J. Super. 266, 272 (App.

Div. 2015) (quoting State v. Ruffin, 371 N.J. Super.

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Related

State v. Ferrante
268 A.2d 301 (New Jersey Superior Court App Division, 1970)
State v. Ruffin
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State v. Schmidt
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Flagg v. Essex County Prosecutor
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State v. Schmidt
540 A.2d 1256 (Supreme Court of New Jersey, 1988)
State v. Hogan
676 A.2d 533 (Supreme Court of New Jersey, 1996)
In Re the Grand Jury Appearance Request by Loigman
870 A.2d 249 (Supreme Court of New Jersey, 2005)
State v. Vasky
528 A.2d 61 (New Jersey Superior Court App Division, 1987)
State v. Del Fino
495 A.2d 60 (Supreme Court of New Jersey, 1985)
State v. Holsten
539 A.2d 325 (New Jersey Superior Court App Division, 1988)
State of New Jersey v. Datrell T. Williams
117 A.3d 1247 (New Jersey Superior Court App Division, 2015)
State v. Scherzer
694 A.2d 196 (New Jersey Superior Court App Division, 1997)
State v. Twiggs
187 A.3d 123 (Supreme Court of New Jersey, 2018)

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State of New Jersey v. James A. Michaud, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-james-a-michaud-njsuperctappdiv-2026.