STATE OF NEW JERSEY VS. JOHN LOYAL (96-06-2036, ESSEX COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedSeptember 26, 2018
DocketA-2824-15T4
StatusUnpublished

This text of STATE OF NEW JERSEY VS. JOHN LOYAL (96-06-2036, ESSEX COUNTY AND STATEWIDE) (STATE OF NEW JERSEY VS. JOHN LOYAL (96-06-2036, ESSEX COUNTY AND STATEWIDE)) 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 VS. JOHN LOYAL (96-06-2036, ESSEX COUNTY AND STATEWIDE), (N.J. Ct. App. 2018).

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court."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-2824-15T4

STATE OF NEW JERSEY,

Plaintiff-Respondent,

v.

JOHN LOYAL,

Defendant-Appellant. ____________________________

Submitted September 18, 2018 – Decided September 26, 2018

Before Judges Hoffman and Firko.

On appeal from Superior Court of New Jersey, Law Division, Essex County, Indictment No. 96-06-2036.

Joseph E. Krakora, Public Defender, attorney for appellant (Richard Sparaco, Designated Counsel, on the brief).

Theodore Stephens II, Acting Essex County Prosecutor, attorney for respondent (Barbara A. Rosenkrans, Special Deputy Attorney General/Acting Assistant Prosecutor, of counsel and on the brief).

PER CURIAM Defendant John Loyal appeals from the December 4, 2015 Law Division

order denying his petition for post-conviction relief (PCR) without an

evidentiary hearing. We affirm.

I

In connection with the February 7, 1996 shooting death of Carl Watson,

an Essex County grand jury indicted defendant for purposeful or knowing

murder, N.J.S.A. 2C:11-3(a)(1) and (2); aggravated assault by pointing a

firearm, N.J.S.A. 2C:12-1(b)(4); possession of a handgun without a permit,

N.J.S.A. 2C:39-5(b); and possession of a handgun with the intent to use it

unlawfully against the person or property of another, N.J.S.A. 2C:39-4(a). After

defendant's first trial resulted in a mistrial, he moved to dismiss the indictment,

arguing a new trial would result in double jeopardy. The trial court denied the

motion.

A second jury found defendant guilty on all four counts. The trial court

sentenced defendant to life in prison with a thirty-year parole disqualifier on the

murder charge and concurrent sentences on the remaining charges. State v.

Loyal, 164 N.J. 418, 428 (2000).

We affirmed defendant's convictions and sentence on direct appeal. State

v. Loyal, No. A-1404-97 (App. Div. July 9, 1999) (slip op. at 22). Our Supreme

A-2824-15T4 2 Court granted certification, and also affirmed. Loyal, 164 N.J. at 443.

Subsequently, the United States District Court for the District of New Jersey

denied defendant's petition for a writ of habeas corpus. In 2003, the Third

Circuit Court of Appeals denied defendant's application for a certificate of

appealability. In 2004, the United States Supreme Court denied defendant's

application for a petition for writ of certiorari.

On July 8, 2014, defendant filed a pro se petition for PCR, and designated

PCR counsel subsequently filed a supporting brief. On December 4, 2015, the

PCR judge delivered an oral opinion denying defendant's petition without an

evidentiary hearing. This appeal followed.

On appeal, defendant argues:

POINT I — DEFENDANT WAS ENTITLED TO AN EVIDENTIARY HEARING[.]

A. DEFENDANT ESTABLISHED A PRIMA FACIE CASE OF INEFFECTIVE ASSISTANCE OF COUNSEL IN TRIAL COUNSEL'S FAILURE TO CALL A CRITICAL WITNESS (SHARONDA POSEY) AT THE RETRIAL.

B. TRIAL COUNSEL WAS INEFFECTIVE IN FAILING TO PROPERLY AND EFFECTIVELY IMPEACH THE CREDIBILITY OF STATE'S WITNESS WANDA COLON.

A-2824-15T4 3 C. APPELLATE COUNSEL WAS INEFFECTIVE IN FAILING TO RAISE ON APPEAL THAT DEFENDANT WAS ENTITLED TO A JURY INSTRUCTION ON CROSS-RACIAL IDENTIFICATION.

D. TRIAL COUNSEL FAILED TO CONDUCT ADEQUATE PRETRIAL INVESTIGATION OF THE CASE RESULTING IN THE FAILURE TO CALL THREE ESSENTIAL WITNESSES AT TRIAL, THEREBY DENYING DEFENDANT THE RIGHT TO EFFECTIVE ASSISTANCE OF COUNSEL.

i. TRIAL COUNSEL WAS INEFFECTIVE IN FAILING TO CALL JEFFREY WISE AS A WITNESS FOR THE DEFENSE.

ii. TRIAL COUNSEL WAS INEFFECTIVE IN FAILING TO CALL VALERIE FIELDS AS A WITNESS FOR THE DEFENSE.

iii. TRIAL COUNSEL WAS INEFFECTIVE IN FAILING TO CALL ALJIVA A[.] POSEY AS A WITNESS FOR THE DEFENSE.

POINT II — DEFENDANT'S PETITION WAS NOT TIME BARRED UNDER R[ULE] 3:22-12.

II

We first consider defendant's argument that the PCR court erred in

determining his PCR petition was time-barred. We reject his argument.

Under Rule 3:22-12(a)(1), a petition for PCR, for reasons other than to

correct an illegal sentence, must be filed within five years of entry of the

A-2824-15T4 4 judgment of conviction, unless there is a showing of excusable neglect. State v.

Afanador, 151 N.J. 41, 52 (1997). "In the context of [PCR], a court should only

relax the bar of Rule 3:22-12 under exceptional circumstances." Ibid.

Here, defendant claims the delay in filing his PCR petition resulted from

excusable neglect. He alleges he filed the petition within seven months after the

Supreme Court denied his application for a petition for writ of certiorari;

however, when he contacted the court after the federal appeals process ended,

he learned a record of his filing did not exist. He further contends he relied upon

his counsel to file for PCR, and therefore, was unaware of the five-year

limitation.

We find defendant's allegations insufficient to warrant relaxing the time-

bar. Defendant's judgment of conviction was entered on September 8, 1997,

therefore, he had until September 2002 to timely file his PCR petition. The

Supreme Court denied certiorari in 2004. Accordingly, even had defendant filed

his PCR petition within seven months of the Supreme Court's denial, he still

would have filed his petition beyond the five-year time-bar. See also State v.

Milne, 178 N.J. 486, 494 (2004) (holding federal habeas corpus proceedings

"ordinarily" do not toll the Rule 3:22-12 time-bar). Moreover, defendant's

assertion that he was unaware of the time-bar fails to constitute excusable

A-2824-15T4 5 neglect. See State v. Murray, 162 N.J. 240, 246 (2000) (holding a lack of

"sophistication in the law does not satisfy the exceptional circumstances

required" to overcome the time-bar).

III

We analyze ineffective assistance of counsel claims by using the two -

prong test established by the Supreme Court in Strickland v. Washington, 466

U.S. 668, 694 (1984). See State v. Preciose, 129 N.J. 451, 463(1992); see also

State v. Fritz, 105 N.J. 42, 58 (1987). The first prong of the Strickland test

requires a defendant to establish counsel's performance was deficient. Preciose,

129 N.J. at 463. "The second, and far more difficult, prong . . . is whether there

exists 'a reasonable probability that, but for counsel's unprofessional errors, the

result of the proceeding would have been different.'" Id. at 463-64 (quoting

Strickland, 466 U.S. at 694).

There exists a strong presumption that counsel rendered adequate

assistance and made all significant decisions in the exercise of reasonable

professional judgment. Strickland, 466 U.S. at 689. Further, because prejudice

is not presumed, defendant must demonstrate how specific errors of counsel

undermined the reliability of the proceeding. Fritz, 105 N.J. at 61.

A-2824-15T4 6 Defendant's substantive arguments lack persuasion. His first argument,

that trial counsel was ineffective in failing to call Sharonda Posey1 as a witness

at the second trial, fails to satisfy the first Strickland prong. At the first trial,

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Cummings
728 A.2d 307 (New Jersey Superior Court App Division, 1999)
State v. Fritz
519 A.2d 336 (Supreme Court of New Jersey, 1987)
State v. Loyal
753 A.2d 1073 (Supreme Court of New Jersey, 2000)
State v. Cromedy
727 A.2d 457 (Supreme Court of New Jersey, 1999)
State v. Milne
842 A.2d 140 (Supreme Court of New Jersey, 2004)
State v. Murray
744 A.2d 131 (Supreme Court of New Jersey, 2000)
State v. Preciose
609 A.2d 1280 (Supreme Court of New Jersey, 1992)
State v. Afanador
697 A.2d 529 (Supreme Court of New Jersey, 1997)

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STATE OF NEW JERSEY VS. JOHN LOYAL (96-06-2036, ESSEX COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-vs-john-loyal-96-06-2036-essex-county-and-statewide-njsuperctappdiv-2018.