State of New Jersey v. Tyhan Brown

New Jersey Superior Court Appellate Division·Decided August 10, 2026·No. A-0299-24·Unpublished

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-0299-24

STATE OF NEW JERSEY, Plaintiff-Respondent,

v.

TYHAN BROWN, a/k/a/ TYHAM BROWN,

Defendant-Appellant.

Submitted May 19, 2026 – Decided August 10, 2026 Before Judges Gooden Brown and Rose.

On appeal from the Superior Court of New Jersey, Law Division, Camden County, Indictment No. 16-12-3622.

Jennifer N. Sellitti, Public Defender, attorney for appellant (Frank M. Gennaro, Designated Counsel, on the brief).

Grace C. MacAulay, Camden County Prosecutor, attorney for respondent (Jason Magid, Assistant Prosecutor, of counsel and on the brief).

Appellant filed a supplemental brief on appellant's behalf.

PER CURIAM Defendant Tyhan Brown appeals from a July 31, 2024 order denying his petition for post-conviction relief (PCR) without an evidentiary hearing. We affirm.

I.

In 2018, a jury convicted defendant of conspiracy to commit murder, attempted murder, aggravated manslaughter as a lesser-included offense of murder, and related weapons offenses for his role in the shooting death of an innocent eight-year-old girl. Defendant was sentenced to an aggregate fifty- one-year prison term, subject to the No Early Release Act, N.J.S.A. 2C:43-7.2, on the attempted murder and aggravated manslaughter convictions. We affirmed defendant's convictions, but remanded for resentencing solely for the trial judge to address the overall fairness of the sentence pursuant to State v. Torres, 246 N.J. 246 (2021). On remand, the judge imposed the same sentence. The Supreme Court denied defendant's ensuing petition for certification. State v. Brown, 249 N.J. 442 (2022).

We incorporate by reference the evidence adduced at trial, summarized in our prior opinion. State v. Brown, No. A-0876-18 (App. Div. Oct. 8, 2021) (slip op. at 4-12). Pertinent to this appeal, on August 24, 2016, at approximately 8:30

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p.m., Gabrielle Hill-Carter (Gabby) was fatally shot in the head in front of her home and died two days later. Id. at 4. The State alleged defendant killed Gabby while attempting to target a rival gang member, Amir Dixon. Id. at 4-5. The State further asserted defendant and Dixon were involved in "an ongoing gang- related dispute documented on social media." Id. at 5.

During the multiday trial, the State presented the testimony of defendant's friend, John Burgos, who claimed he had no recollection of his prior statement to police. Id. at 10. At sidebar, during direct examination, trial counsel requested a Gross1 hearing, but the court denied his application. Ibid. At the conclusion of the State's questioning, the court granted trial counsel's application to admit the unredacted video recording of Burgos's statement "in lieu of a Gross hearing being conducted." Id. at 11. In his statement, Burgos said defendant told him that he tried to shoot Dixon, but his weapon jammed. Ibid.

The State also called Michael Jones, who denied some of his prior statements to police. Ibid. Following a Gross hearing, Jones' recorded video statements with redactions were played for the jury. Id. at 11-12. We glean from the record, in an unredacted portion of his statement, Jones told police he

1 State v. Gross, 121 N.J. 1 (1990).

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was not present at the shooting, but his friend Ralph Johnson told him defendant and others shot at Johnson and Dixon, ultimately striking Gabby. On cross- examination Jones claimed his statements were all "hearsay and lies." Id. at 12.

The State also called FBI Special Agent William Shute who testified his forensic analysis of defendant's phone revealed it was "in 'close proximity' to the murder scene" at the time of the shooting. Id. at 9. Although there were no eyewitnesses to the shooting, the State presented the testimony of defendant's cellmate, Emmett Tolbert, who testified defendant told him he shot a gang member with a revolver. Ibid.

On direct appeal, defendant argued the trial court erroneously admitted "'multiple inadmissible hearsay statements' during the testimony of Jones [and] Burgos." Id. at 12. We rejected defendant's argument, concluding the judge properly determined Jones' "prior statements were admissible subject to redaction" because Jones was "feigning ignorance" on the witness stand. Id. at 14-15. We noted Jones' reference to Johnson's statement was "fleeting in the context of Jones' entire statement, was confusing as to whom it accused of the shooting, and its admission was not plain error." Id. at 15 n.6. We also concluded any error in the introduction of Burgos's statement was harmless

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under the invited error doctrine because defense counsel asked the judge to play Burgos's unredacted recorded statement in open court. Id. at 15.

Defendant filed a timely self-represented petition for PCR without specifying a ground for relief. Thereafter, assigned counsel filed a brief on defendant's behalf, contending trial counsel was ineffective by failing to: (1) object to hearsay and prejudicial statements contained in the recorded statements of Jones and Burgos; (2) present evidence to explain defendant's cell phone was located near the crime because his family lived nearby, supported by his affidavit stating he informed trial counsel his family resided near the crime scene; and (3) object to the prosecutor's remark in summation that defendant was present at the crime scene and a bullet was fired from his direction.

During oral argument on the petition, PCR counsel explained defendant's "main argument" was trial "counsel not only didn't object to very prejudicial, non-probative testimony, in fact, he asked the court to admit it." PCR counsel elaborated:

And the issue is not whether the hearsay statements themselves should have come in, because that's already been decided by the Appellate Division.

The issue is whether the prejudicial statements within those hearsay statements should have been objected to, should have been excised through a Gross hearing, and that was not raised on appeal at all. The

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troubling statements were that the witness, Mr. Burgos, was afraid . . . defendant would kill him for cooperating. He said, "I fear for my life" nine times . . . in his statement. He said, "I'm scared they will hurt me. I'm scared to say what happened. I'm just scared man. I'm scared, bro. I'm scared, honestly, man. They will kill me, man."

....

And the witness, Mr. Jones, sort of corroborated that in his statement, saying, "No matter if you tell them that or not, he's not going to tell," referring to Burgos, "He can get tortured, you fuck around and get killed for that. He'd be risking his life."

All of that would be bad enough, would be prejudicial enough, has no probative value, but the detective made it worse. The detective said, "I know you're scared, I get it." He said that twice in Mr. Burgos's statement.

All of that together painted an inappropriate picture of [defendant] as dangerous, while adding nothing of evidential value. None of that had to do with whether [defendant] was present when Gabby . . . was shot. But then the detective made it worse, because he said to Mr. Burgos, "I understand you're scared. As of right now, today, I'm telling you, you will not go to Camden County, okay?" So that emphasized that Mr. Burgos should be scared, but also told the jury that the defendant was incarcerated. It was tantamount to bringing him out in an orange jumpsuit.

Of course, highly prejudicial evidence with no probative value is not admissible, and evidence that a defendant is generally dangerous is not admissible under Rule 404. So, it's not that the statement should've

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