State of New Jersey v. Malihki X. Oliver

CourtNew Jersey Superior Court Appellate Division
DecidedAugust 12, 2025
DocketA-3118-23
StatusPublished

This text of State of New Jersey v. Malihki X. Oliver (State of New Jersey v. Malihki X. Oliver) 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. Malihki X. Oliver, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3118-23

STATE OF NEW JERSEY, APPROVED FOR PUBLICATION August 12, 2025 Plaintiff-Respondent, APPELLATE DIVISION

v.

MALIHKI X. OLIVER,

Defendant-Appellant. ________________________

Submitted May 29, 2025 – Decided August 12, 2025

Before Judges Mayer, Rose and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County, Indictment No. 22-10-0137.

John W. Hartmann, attorney for appellant.

Matthew J. Platkin, Attorney General, attorney for respondent (Regina M. Oberholzer, Deputy Attorney General, of counsel and on the brief).

The opinion of the court was delivered by

ROSE, J.A.D. This appeal requires us to determine, as a matter of first impression, the

elements of second-degree purchasing firearm parts to manufacture a firearm

without a serial number, N.J.S.A. 2C:39-9(k) (Paragraph k), and the application

of the territorial jurisdiction statute, N.J.S.A. 2C:1-3. In October 2022, a State

grand jury issued a four-count indictment, charging defendant Malihki X. Oliver

with conspiracy and weapons offenses for his part in purchasing multiple "ghost

gun"1 kits in Pennsylvania and transporting the kits to New Jersey with the

purpose to assemble firearms. Defendant was arrested after New Jersey State

Police (NJSP) stopped his car near his Trenton address. Police also arrested

Raheem Tucker, a Pennsylvania resident, who was driving defendant's car when

it was stopped.

After he was indicted, defendant unsuccessfully moved to dismiss the first

two counts of the indictment: second-degree conspiracy to purchase firearm

parts not imprinted with a serial number and transport large capacity

ammunition magazines, N.J.S.A. 2C:5-2, and :39-9(k) and (h) (count one); and

second-degree purchasing firearm parts not imprinted with a serial number with

1 See United States v. Bishoff, 58 F.4th 18, 20 n.2 (1st Cir. 2023) (defining "ghost guns" as "firearms sold as sets of parts that can be assembled at home, and that typically lack markings such as serial numbers").

A-3118-23 2 the purpose to manufacture a firearm without a license to do so, N.J.S.A. 2C:39-

9(k) and :2-6 (count two).2 In a written statement of reasons annexed to the

February 21, 2023 order denying relief, the motion judge rejected defendant's

contentions that the Deputy Attorney General's (DAG) grand jury instructions

on the elements of Paragraph k were erroneous, the State failed to satisfy the

elements of Paragraph k, and the DAG improperly "expressed her opinion"

during the presentation and therefore failed to satisfy "the State's fair play

obligation."

Defendant thereafter pled guilty to count two before the same judge who

denied his motion. Pursuant to the terms of the negotiated plea agreement,

defendant was sentenced as a third-degree offender to a three-year prison term,

and the remaining counts of the present indictment and all counts of another

indictment were dismissed.3

2 The remaining counts charged: fourth-degree unlawful possession of a large capacity ammunition magazine, N.J.S.A. 2C:39-3(j) (count three); and fourth- degree transporting two large capacity ammunition magazines, N.J.S.A. 2C:39 - 9(h) and :2-6 (count four). 3 We glean from the plea hearing transcript, during the factual basis for his guilty plea, defendant exculpated Tucker and the charges in the present indictment were to be dismissed against Tucker after defendant's sentencing. Another judge sentenced defendant. The sentencing transcript does not reflect the charges against Tucker were dismissed but he is not a party to this appeal. A-3118-23 3 On appeal, defendant reprises the following arguments for our

consideration:

POINT I

THE [TRIAL] COURT ERRED IN FINDING THE STATE PRESENTED PRIMA FACIE EVIDENCE AS TO EACH ELEMENT OF COUNTS I AND II OF THE INDICTMENT AND IN FINDING THAT TERRITORIAL JURISDICTION EXISTED.

A. The [Trial] Court Erred in Concluding that Since the State Read the Statute to the Grand Jury that the Elements of the Offense are Irrelevant Because the State Was Not Blatantly Wrong and Should Have Concluded that there is One Element.

B. The [Trial] Court Erred in Finding that The Elements of [Paragraph k] Were Supported by Prima Facie Evidence.

C. The [Trial] Court erred in its Application of the Territorial Jurisdiction Statute.

POINT II

THE [TRIAL] COURT ERRED IN NOT DISMISSING THE INDICTMENT BECAUSE THE STATE VIOLATED ITS OBLIGATION TO PRESENT THE CASE IN A FAIR MANNER WHEN THE DAG MISINFORMED THE GRAND JURY ABOUT THE ELEMENTS, ADVISED THEM THAT THE PARTIES MERE PRESENCE IN THE STATE SATISFIED AN ELEMENT AND LIMITED THE JURORS' QUESTIONS.

A-3118-23 4 Unpersuaded by these contentions, we affirm.

I.

We summarize the facts from the testimony adduced at the grand jury

hearing, "viewing the evidence and the rational inferences drawn from that

evidence in the light most favorable to the State."4 State v. Morrison, 188 N.J.

2, 13 (2006). The evidence was presented through the State's sole witness,

Detective Gregory Woods of the Trenton Police Department, who was "on loan"

to the NJSP Crime Suppression Unit and the Realtime Crime Center Intel Unit

at the time of the incident.

Before calling Woods to testify, the DAG instructed:

[L]et me stress that anything I say is not evidence and should not be considered by you as evidence. The evidence regarding the alleged facts in this matter will be presented to you through the testimony of witnesses. There will be no exhibits in this presentation. Therefore, you should not consider anything that I tell you as evidence. In the end, any decision of whether or not to indict, who to indict, if anyone, and on what crimes, if any, is yours. The brief factual background that I'm going to read to you is merely to acquaint you with the facts of the case so you have a context for this testimony. Again, this is not evidence. All of the evidence is going to come from the witness in this case.

4 In doing so, we reject the State's counterstatement of facts to the extent it cites the factual basis supporting defendant's guilty plea where those facts were not adduced at the grand jury hearing. A-3118-23 5 I would like also to remind you that you're here to consider the evidence and the law presented here and only here.

The DAG then provided a brief factual background regarding the incident.

She also read the proposed indictment and applicable statutes.

Woods testified on July 30, 2022, the New York State Police (NYSP) and

Pennsylvania Attorney General's Office jointly worked an interdiction detail at

a gun show in Trevose, Pennsylvania. NYSP Investigator Christian Spears,

stationed at the show's exit door, was assigned "to look for out-of-state targets"

who purchased ghost gun kits and "advise the appropriate state authorities so

that the purchasers could be investigated further." Woods explained ghost gun

kits were legally sold in Pennsylvania.

Woods further testified Spears witnessed defendant and Tucker purchase

multiple kits from a vendor, which did "not require identification or paperwork"

and sold the kits "on a cash basis." Spears did not observe whether defendant

or Tucker paid for the kits but Spears saw both men "participating in the sale

and hear[d] both negotiating the price." Spears followed the men to the parking

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