State of New Jersey v. Katherine G. Stephens

CourtNew Jersey Superior Court Appellate Division
DecidedApril 24, 2026
DocketA-3330-24
StatusUnpublished

This text of State of New Jersey v. Katherine G. Stephens (State of New Jersey v. Katherine G. Stephens) 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. Katherine G. Stephens, (N.J. Ct. App. 2026).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3330-24

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

KATHERINE G. STEPHENS,

Defendant-Appellant. ___________________________

Submitted April 14, 2026 – Decided April 24, 2026

Before Judges Perez Friscia and Vinci.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. 24-09-1681.

Louis G. DeAngelis, LLC, attorney for appellant (Louis G. DeAngelis, of counsel and on the briefs; Jeffrey Zajac, on the briefs).

Theodore N. Stephens II, Essex County Prosecutor, attorney for respondent (Frank J. Ducoat, Deputy Chief Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant Katherine G. Stephens appeals from a May 15, 2025 trial court

order denying her motion for a civil reservation pursuant to Rule 3:9-2 after she

pleaded guilty to fourth-degree neglect of a child, N.J.S.A. 9:6-3, as a condition

to entering the pretrial intervention (PTI) program, N.J.S.A. 2C:43-12. For the

reasons that follow, we reverse and remand for further proceedings in

accordance with Rule 3:9-2 and State v. Lavrik, 472 N.J. Super. 192 (App. Div.

2022).

On February 28, 2024, defendant, who was seventy-four years old, was

employed as a bus driver for a private company that transports children with

disabilities. Newark Police Department (NPD) officers responded to the

Regional Day School after receiving a report that J.B., a fifteen-year-old student

with autism, was missing. 1 J.B.'s mother, B.N., "received a call from the school

at approximately 3:15 [p.m.] asking why her son . . . was not in school." She

reported J.B. "had been picked up by the school bus" at 7:15 a.m.

The school's attempts to contact defendant and the bus aide, Judith Bey,

were unsuccessful. Defendant and Bey arrived at the school with J.B. at

approximately 3:20 p.m. They reported that after J.B. boarded the school bus,

1 We use initials to protect J.B.'s medical records, report, and evaluations. R. 1:38-3(a)(2). A-3330-24 2 they had "pick[ed] up the rest of the students" and "walked the students out of

the bus," but did "not notic[e] that [J.B.] had been left behind." When they

returned to the school later that afternoon, they discovered J.B. had been alone

on the bus since 7:15 a.m. J.B. had no observed injuries.

On September 4, 2024, defendant was indicted by a grand jury and

charged with second-degree endangering the welfare of a child, N.J.S.A. 2C:44-

4(a)(2), and fourth-degree neglect of a child. On October 22, 2024, defendant

applied for PTI. The State consented to her admission to PTI contingent on her

entering a guilty plea, providing truthful testimony against Bey, and maintaining

no contact with J.B. Additionally, defendant's guilty plea would only be vacated

after successful completion of PTI.

On January 7, 2025, defendant pleaded guilty to fourth-degree neglect of

a child as a condition of entering into PTI. The same day, the trial court entered

an order of postponement admitting her to PTI for a term of eighteen months.

On January 29, 2025, defendant filed a motion for a civil reservation of

her PTI guilty plea. The State did not oppose the motion. She submitted a

certification requesting the court grant a civil reservation because she was "a

[seventy-four-year-old] widow" who "live[d] alone in a [s]enior [h]ealth

building" and "[u]p until the incident, [she] ha[d] lived a law[-]abiding life."

A-3330-24 3 She had been unable to work since the incident and her "only source of income

[was] [s]ocial [s]ecurity." Defendant reported having no "savings accounts,"

"stocks, bonds, or assets," and she would be "financially destroyed" if a civil

damages award was entered against her.

On May 15, 2025, after hearing oral argument, the court entered an order

denying defendant's motion for a civil reservation supported by an oral decision.

The court stated it was "not compelled to grant" the motion because it was "not

going to speculate as to what potential claims . . . plaintiff could have" and

would "not . . . foreclose any potential[]" claims. The court determined the

motion was "premature" and "if there[ is] a civil action that is filed . . . then [the

motion] would be addressed at that point." This appeal followed.

On appeal, defendant raises the following arguments:

POINT I

BECAUSE THERE IS NO REQUIREMENT FOR A PENDING CIVIL ACTION, THE LAW DIVISION'S DENIAL OF THE DEFENDANT'S REQUEST FOR A CIVIL RESERVATION CONSTITUTES REVERSIBLE ERROR.

A. The Defendant Has Satisfied the Good Cause Standard Under Rule 3:9-2.

B. The Law Division Erred By Requiring the Filing of a Civil [Lawsuit] Prior to Granting a Civil Reservation Under Rule 3:9-2.

A-3330-24 4 We review a trial court's interpretation of court rules de novo. State v.

Anthony, 443 N.J. Super. 553, 564 (App. Div. 2016). Whether a civil

reservation is supported by good cause is a legal question also subject to de novo

review. State v. McIntyre-Caulfield, 455 N.J. Super. 1, 5 (App. Div. 2018);

Lavrik, 472 N.J. Super. at 213.

Guilty pleas in criminal proceedings may be admissible in civil cases as

statements of a party opponent under N.J.R.E. 803(b)(1). Maida v. Kuskin, 221

N.J. 112, 125 (2015). Rule 3:9-2 authorizes civil reservations and provides,

"[f]or good cause shown the court may, in accepting a plea of guilty, order that

such plea not be evidential in any civil proceeding." "The purpose of [Rule 3:9-

2] is to avoid an unnecessary criminal trial of a defendant who fears that a civil

claimant will later use [their] plea of guilty as a devastating admission of civil

liability." McIntyre-Caulfield, 455 N.J. Super. at 8 (first alteration in original)

(quoting Stone v. Police Dep't of Keyport, 191 N.J. Super. 554, 558 (App. Div.

1983)).

The "good cause" standard may be satisfied where it is: "necessary to

remove an obstacle to a defendant's pleading guilty to a criminal charge"; or "the

civil consequences of a plea may wreak devastating financial havoc on a

defendant." Id. at 9 (first quoting State v. Haulaway, Inc., 257 N.J. Super. 506,

A-3330-24 5 508 (App. Div. 1992); and then quoting State v. Tsilimidos, 364 N.J. Super. 454,

459 (App. Div. 2003)). The burden of establishing good cause is on the

defendant. Maida, 221 N.J. at 123.

We are convinced the court improperly denied defendant's motion for a

civil reservation because no civil suit was pending against her. Rule 3:9-2

provides that a defendant shall move for a civil reservation for "good cause

shown" when the court is "accepting a plea of guilty." In McIntyre-Caulfield

we determined:

the plain text of [Rule 3:9-2], and the case law interpreting it, does not make its applicability dependent on a filed lawsuit. The lack of a pending civil lawsuit is not determinative. . . . Making eligibility for a Rule 3:9-2 request dependent on the filing of a civil complaint—something that is beyond the control of a defendant—is beyond the scope of the rule.

[455 N.J. Super. at 9.]

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Related

State v. Tsilimidos
837 A.2d 373 (New Jersey Superior Court App Division, 2003)
Bruce Maida v. Michael Kuskin (073429)
110 A.3d 867 (Supreme Court of New Jersey, 2015)
State of New Jersey v. Reginald Anthony
129 A.3d 1085 (New Jersey Superior Court App Division, 2016)
State v. McIntyre-Caulfield
187 A.3d 171 (New Jersey Superior Court App Division, 2018)
Stone v. Police Department of Keyport
468 A.2d 442 (New Jersey Superior Court App Division, 1983)
State v. Haulaway, Inc.
608 A.2d 964 (New Jersey Superior Court App Division, 1992)

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