State of New Jersey v. Theodore Brown, Jr.

CourtNew Jersey Superior Court Appellate Division
DecidedOctober 16, 2025
DocketA-3397-23
StatusUnpublished

This text of State of New Jersey v. Theodore Brown, Jr. (State of New Jersey v. Theodore Brown, Jr.) 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. Theodore Brown, Jr., (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-3397-23

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

THEODORE BROWN, JR., a/k/a THEODORE BROWN, T. BROWN, THEODORE J. BROWN, and TED BROWN,

Defendant-Appellant.

Submitted September 18, 2025 – Decided October 16, 2025

Before Judges Mawla and Marczyk.

On appeal from the Superior Court of New Jersey, Law Division, Burlington County, Indictment No. 15-06- 0750.

Jennifer N. Sellitti, Public Defender, attorney for appellant (Steven E. Braun, Designated Counsel, on the brief).

LaChia L. Bradshaw, Burlington County Prosecutor, attorney for respondent (Alexis R. Agre, Assistant Prosecutor, of counsel and on the brief). PER CURIAM

Defendant Theodore Brown, Jr. appeals from the trial court's April 30,

2024 order denying his application for post-conviction relief (PCR). We affirm.

I.

In June 2015, defendant was indicted and charged with: two counts of

first-degree robbery, N.J.S.A. 2C:15-1(a)(2) (counts one and two); first-degree

attempted robbery, N.J.S.A. 2C:5-1(a)(1) and 2C:15-1(a)(2) (count three); three

counts of second-degree possession of a weapon for an unlawful purpose,

N.J.S.A. 2C:39-4(a)(1) (counts four, five, and six); three counts of third-degree

unlawful possession of a weapon, N.J.S.A. 2C:39-5(b)(2) (counts seven, eight,

and nine); and three counts of second-degree certain persons not to have

weapons, N.J.S.A. 2C:39-7(b)(1) (counts ten, eleven, and twelve).

In August 2015, defendant pled guilty to count two of the indictment. In

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

charges and to recommend a fourteen-year prison sentence, subject to the No

Early Release Act (NERA), N.J.S.A. 2C:43-7.2.

During the plea hearing, defendant testified that on September 26, 2014,

he traveled to a gas station in Moorestown, where he used a gun the victim

A-3397-23 2 believed to be real, and stole money from the victim that belonged to the gas

station, along with an iPad.

During the investigation of the robbery, the Moorestown police

interviewed defendant. He was advised of his Miranda1 rights and signed a

Miranda card. Defendant did not consent to a search of his apartment but did

consent to a buccal swab for DNA testing of a mask that was recovered

following a robbery at a different store. The police ultimately obtained a warrant

to search defendant's apartment, where they found clothing worn by defendant

during the gas station robbery and a gun under his bed.

Defense counsel acknowledged the strength of the State's case and the fact

defendant faced the possibility of an extended-term sentence if convicted of all

the charges. He further noted defendant had mental health issues, which were

considered as part of the negotiated plea, and requested defendant receive

counseling in prison. Counsel acknowledged defendant faced a possible

sentence of more than forty years in prison, if convicted of all the charges.

The court sentenced defendant to a fourteen-year term of imprisonment,

subject to NERA. Defendant appealed, challenging his sentence and arguing,

1 Miranda v. Arizona, 384 U.S. 436 (1966). A-3397-23 3 among other issues, the trial court should have considered mitigating factor four.

We affirmed the sentence.

Defendant subsequently moved for PCR in October 2022, and counsel was

assigned to represent him. 2 In November 2023, counsel filed an amended

verified petition and brief. On April 30, 2024, the court denied defendant's PCR

application.

II.

On appeal, defendant raises the following point:

AN EVIDENTIARY HEARING IS NECESSARY BECAUSE DEFENSE COUNSEL WAS INEFFECTIVE BY FAILING TO CHALLENGE DEFENDANT'S STATEMENT, HIS CONSENT TO THE POLICE USE OF A BUCCAL SWAB, AND FOR

2 Defendant, who was previously self-represented, attempted on numerous prior occasions to apply for PCR and other relief. In January 2017, he submitted a letter requesting PCR. The application was denied. He submitted another letter in late January 2017, which the court construed as a motion to withdraw a guilty plea and denied. In August 2017, defendant forwarded correspondence to the court requesting a reduction of his sentence, which was also denied. In November 2017, defendant filed another letter requesting his case be reopened—construed by the court as a motion to withdraw a guilty plea—and that application was denied. Defendant again unsuccessfully moved to reduce his sentence in December 2017. His motion for a reduction of his sentence in April 2020 was also denied. In October 2020, defendant filed another unsuccessful PCR petition. He again requested a reduction in sentence in September 2021, which was denied. In June 2022, defendant filed what was interpreted by the court as a second PCR petition, and that application was denied in September 2022. A-3397-23 4 FAILING TO ADEQUATELY ADDRESS MITIGATING FACTORS.

A. Counsel failed to consider how defendant's mental health issues impacted his supposed consent to interrogation.

B. Counsel failed to challenge defendant's consent to the buccal swab.

C. Counsel failed to adequately argue the mitigating factors.

We review a PCR court's conclusions of law de novo. State v. Nash, 212

N.J. 518, 540-41 (2013). We must affirm the PCR court's factual findings unless

they are not supported by "sufficient credible evidence in the record." Id. at

540. A judge's decision to deny a PCR petition without an evidentiary hearing

is reviewed under an abuse of discretion standard; however, we may review the

factual inferences and legal conclusions drawn by the court de novo. State v.

Brewster, 429 N.J. Super. 387, 401 (App. Div. 2013) (citing State v. Marshall,

148 N.J. 89, 157-58 (1997)); State v. Blake, 444 N.J. Super. 285, 294 (App. Div.

2016).

To establish a claim of ineffective assistance of counsel, a defendant must

satisfy the two-prong Strickland test: (1) "counsel made errors so serious that

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

Sixth Amendment" and (2) "the deficient performance prejudiced the defense."

A-3397-23 5 Strickland v. Washington, 466 U.S. 668, 687 (1984); see also State v. Fritz, 105

N.J. 42, 58 (1987) (adopting the Strickland two-prong test in New Jersey). A

defendant must establish both prongs by a preponderance of the evidence. State

v. Gaitan, 209 N.J. 339, 350 (2012).

As to the first prong, the Constitution requires "reasonably effective

assistance," so an attorney's performance may not be attacked unless they did

not act "within the range of competence demanded of attorneys in criminal

cases," and instead "fell below an objective standard of reasonableness."

Strickland, 466 U.S. at 687-88 (internal citation omitted) (quoting McMann v.

Richardson, 397 U.S. 759, 770-71 (1970)). When assessing the first Strickland

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