State of New Jersey v. Joseph Centanni

CourtNew Jersey Superior Court Appellate Division
DecidedJune 27, 2025
DocketA-3281-23
StatusUnpublished

This text of State of New Jersey v. Joseph Centanni (State of New Jersey v. Joseph Centanni) 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. Joseph Centanni, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3281-23

STATE OF NEW JERSEY,

Plaintiff-Appellant,

v.

JOSEPH CENTANNI,

Defendant-Respondent. _________________________

Argued June 4, 2025 – Decided June 27, 2025

Before Judges Mayer, Rose and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Union County, Indictment No. 22-12-0903.

Milton S. Leibowitz, Assistant Prosecutor, argued the cause for appellant (William A. Daniel, Union County Prosecutor, attorney; Milton S. Leibowitz, of counsel and on the briefs).

Joseph A. Hayden, Jr., argued the cause for respondent (Pashman Stein Walder Hayden, attorneys; Joseph A. Hayden, Jr., Brendan M. Walsh, and Dominique Kilmartin, of counsel and on the brief).

PER CURIAM The State appeals from a June 11, 2024 Law Division order dismissing

without prejudice a forty-two-count Union County indictment charging

defendant Joseph Centanni with twenty-three counts of second-degree sexual

assault by force or coercion, without inflicting severe personal injury, N.J.S.A.

2C:14-2(c)(1),1 and nineteen counts of fourth-degree criminal sexual contact by

force or coercion, without inflicting severe personal injury, N.J.S.A. 2C:14-

3(b).2 In its presentation to the grand jury, the State alleged, for a decade,

defendant used his position as a landlord to force or coerce various financially

struggling tenants to perform sexual favors in exchange for securing an

apartment or retaining an apartment if they were in arrears.

In a lengthy written decision accompanying the order, the motion court

separated the counts into three categories: "clearly valid counts"; "clearly

invalid counts"; and "most significantly contested counts." For the reasons that

follow, we reverse the court's dismissal of the clearly valid counts; reverse in

1 Counts one, three, six, eight, ten, thirteen, fifteen, nineteen, twenty-one, twenty-three, twenty-six, twenty-seven, twenty-nine, thirty, thirty-two, thirty- three, thirty-five, thirty-seven, thirty-eight, thirty-nine, forty, forty-one, and forty-two. 2 Counts two, four, five, seven, nine, eleven, twelve, fourteen, sixteen, seventeen, eighteen, twenty, twenty-two, twenty-four, twenty-five, twenty- eight, thirty-one, thirty-four, and thirty-six. A-3281-23 2 part the court's dismissal of the most significantly contested counts under the

State's physical force theory; and affirm the court's dismissal of the clearly

invalid counts.

I.

We summarize the pertinent facts from the motion record "in a light most

favorable to the State." State v. Twiggs, 233 N.J. 513, 544 (2018). In December

2022, the State commenced the grand jury presentation at issue by summarizing

the allegations and explaining its theory of liability. After ascertaining the grand

jury previously considered sex crimes during its term, the prosecutor recited the

proposed charges, and issued instructions on those charges consistent with the

relevant statutes and model jury charges. Pertinent to this appeal, the prosecutor

instructed:

[T]he counts involving sexual assault the law is as follows. The section of our statute provides in pertinent part an actor is guilty of sexual assault if he commits an act of sexual penetration with another person, and the actor uses physical force or coercion, but the victim does not sustain severe personal injury.

In order for you to find the defendant committed this offense the State must prove the following elements: 1) defendant committed an act of sexual penetration with another person; 2) defendant acting knowingly; 3) defendant used physical force or coercion; 4) the victim did not sustain severe personal injury.

A-3281-23 3 ....

The third element the State must prove is that the defendant used physical force or coercion. Physical force is defined as the commission of the act of sexual penetration without the victim's freely and affirmatively-given permission to the specific act of penetration alleged to have occurred. You must decide whether the defendant's alleged act of penetration was undertaken in circumstances that left the defendant reasonably to believe that the victim had freely given affirmative permission to the specific act of sexual penetration.

Simply put, affirmatively-given permission means the victim did or said something, which would lead a reasonable person to believe he or she was agreeing to engage in the act of sexual penetration, and freely-given permission means the victim agreed, of his or her own free will, to engage in the act of sexual penetration. Freely and affirmatively-given permission can either be indicated through words or actions that when viewed in light of all of the surrounding circumstances, would demonstrate to a reasonable person that affirmatively and freely-given permission for the specific act of sexual penetration had been given. Persons need not, of course, expressly announce their consent to engage in acts of sexual intercourse for there to be affirmative permission. Permission to engage in an act of sexual penetration can be, and, indeed, often is indicated through physical actions rather than words. Permission is demonstrated when the evidence in whatever form is sufficient to demonstrate that a reasonable person were to believe that the alleged victim had affirmatively and freely given authorization to the act. Proof that the act of sexual penetration occurred without the victim's permission can be based on evidence of conduct or

A-3281-23 4 words in light of the surrounding circumstances, and must demonstrate that the reasonable person would not have believed there was an affirmative and a freely- given permission.

If there's evidence to suggest the defendant reasonably believed that such permission had been given, the State must demonstrate that either the defendant did not actually believe that such permission had been freely given, or that such a belief was unreasonable under all of the circumstances. In determining the reasonableness of defendant's belief that the victim had freely given affirmative permission you must keep in mind that the law places no burden on the alleged victim to have expressed non-consent, or to have denied permission. You should not speculate as to what the alleged victim thought or desired, or why he or she did not resist or protest. The State is not required to prove that the victim resisted.

To find the defendant used coercion you must find that the defendant, with the purpose to unlawfully restrict the victim's freedom of action to engage in, or refrain from engaging in, the act of sexual penetration, threatened to: 1) inflict any bodily injury on anyone, or commit another offense; 2) accuse anyone of an offense; 3) expose any secret which would tend to subject a person to hatred, contempt or ridicule, or to impair his or her credit or business repute; 3) take or withhold action as an official, or cause an official to take or withhold action; 4) – that was No. 4, I'm sorry – or perform any other act which would not in itself substantially benefit the actor but which is calculated to substantially harm another person with respect to his or her health, safety, business, calling, career, financial condition, reputation or personal relationships.

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State of New Jersey v. Joseph Centanni, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-v-joseph-centanni-njsuperctappdiv-2025.