State v. Isaiah Bell (081743) (Somerset County & Statewide)

CourtSupreme Court of New Jersey
DecidedApril 14, 2020
DocketA-58-18
StatusPublished

This text of State v. Isaiah Bell (081743) (Somerset County & Statewide) (State v. Isaiah Bell (081743) (Somerset County & Statewide)) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Isaiah Bell (081743) (Somerset County & Statewide), (N.J. 2020).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court. In the interest of brevity, portions of an opinion may not have been summarized.

State v. Isaiah Bell (A-58-18) (081743)

Argued September 24, 2019 -- Decided April 14, 2020

SOLOMON, J., writing for the Court.

The Court considers whether the prosecutor’s failure to instruct the grand jury on lesser-included offenses for murder in response to questions posed by a grand juror constituted an abuse of prosecutorial discretion warranting dismissal of defendant’s indictment for first-degree murder and possession of a weapon for an unlawful purpose.

Defendant Isaiah Bell was arrested after James Kargbo died from stab wounds apparently inflicted during an altercation that occurred when defendant and his partner arrived at Kargbo’s house to pick up her son. A Somerset County prosecutor asked a grand jury to consider two charges against defendant: murder, a crime of the first degree, and third-degree possession of a weapon for an unlawful purpose. The prosecutor explained the counts and elements of the offenses. A grand juror twice asked whether murder had different degrees, and the prosecutor explained that grand jurors do not determine degrees, only whether the facts presented “fit the elements of the crime.” After several witnesses testified and answered questions, the same grand juror asked, “is there such a thing as second-degree murder?” The prosecutor responded by discussing the grand jury’s responsibilities regarding “lesser included lower offenses,” and the elements of murder. The grand juror asked, “[T]here’s no part of the . . . statute that speaks to premeditation?” The prosecutor confirmed that there was not and read the model jury charge for murder. The grand jury indicted defendant on both counts.

Defendant moved to dismiss the indictment claiming that, because the grand jury asked about lesser-included offenses, the prosecutor should have explained the lesser- included offenses for murder. The court denied the motion, finding that the grand jury was not requesting instructions on lesser-included offenses, but rather “clarification.” The Appellate Division denied defendant’s motion for leave to appeal. The Court granted leave to appeal. 236 N.J. 631 (2019).

HELD: The prosecutor did not impermissibly interfere with the grand jury’s investigative functions. As the trial court found, the grand jury here sought clarification rather than specific instructions on lesser-included offenses for murder. The Court provides guidance as to when such instructions should be given. 1 1. The State moved to dismiss this appeal as moot after defendant was indicted by a second grand jury for the same crimes. Because this is a matter of general public importance, the Court considers the motion. (pp. 5-6)

2. The decision to prosecute and what charge to file or bring before a grand jury generally rests entirely in the prosecutor’s discretion. A deficiency premised upon alleged prosecutorial misconduct does not require dismissal of an indictment unless the prosecutor’s misconduct is extreme and clearly infringes upon the grand jury’s decision- making function. Where a prosecutor’s instructions to the grand jury were misleading or an incorrect statement of law, the indictment fails. (pp. 6-9)

3. Instructions on lesser-included offenses began as a way to aid the prosecution so that it would not fail entirely where some element of the greater offense was not established. In the context of a petit jury, lesser-included-offense instructions also protect the accused by avoiding the coercive prejudice inherent in giving the jury the choice of all-or-nothing. In the grand jury setting, on the other hand, an all-or-nothing choice jeopardizes the prosecution: If the prosecutor does not explain lesser-included offenses to the grand jurors and probable cause is not found for the offense presented, the grand jury will return a no bill. If evidence of lesser-included offenses, though not clearly exculpatory, exists but is not presented to the grand jury, or if the evidence is presented but the grand jury is not instructed on lesser-included offenses, the trial court must nonetheless instruct the petit jury on lesser-included offenses at the close of trial. (pp. 9-12)

4. Courts in other jurisdictions have generally found no affirmative duty to instruct grand juries on lesser-included offenses but have been nearly uniform in ruling that prosecutors may not mislead grand jurors if they pose questions about lesser-included offenses. Applying the principles from the treatment of lesser-included offenses before petit juries, the Court agrees that the constitutional protections afforded defendants by the grand jury process are not undermined by the failure to charge lesser-included offenses. (pp. 12-14)

5. The trial court here did not abuse its discretion in denying defendant’s motion to dismiss the indictment. The facts revealed an altercation while defendant and his partner picked up her child from the victim. In that altercation, defendant allegedly stabbed the victim. In that context, it is reasonable that a grand juror would seek clarification about “degrees” for murder, and specifically about premeditation. In response, the prosecutor mentioned “lesser included lower offenses,” the grand jury’s responsibility, and the model jury charge for murder. The prosecutor made no misstatements or misleading representations. No subversion of the grand jury process occurred. The prosecutor dutifully, honestly, and in good faith answered the grand juror’s questions. That the prosecutor did not instruct the grand jury on lesser-included offenses for murder does not constitute an abuse of the prosecutor’s broad discretion warranting dismissal of the indictment. In any event, the trial court may be obliged to instruct the petit jury on lesser-included offenses at the close of trial. (pp. 14-16) 2 6. Although no instruction as to lesser-included offenses was needed in this case, the Court notes that other cases may call for such instructions. When the grand jurors’ questions, considered in context, ask about lesser-included offenses and there is a rational basis for instructions on lesser-included offenses, the better practice for prosecutors is to provide them and advise the grand jury that the trial court may include instructions on lesser-included offenses whether or not the grand jury authorizes them. That will ensure that grand jurors are fully informed of the consequences of their decisions. (pp. 16-17)

The decision of the trial court is AFFIRMED.

CHIEF JUSTICE RABNER and JUSTICES LaVECCHIA, ALBIN, PATTERSON, FERNANDEZ-VINA, and TIMPONE join in JUSTICE SOLOMON’S opinion.

3 SUPREME COURT OF NEW JERSEY A-58 September Term 2018 081743

State of New Jersey,

Plaintiff-Respondent,

v.

Isaiah Bell,

Defendant-Appellant.

On appeal from the Superior Court, Appellate Division.

Argued Decided September 24, 2019 April 14, 2020

Isaac Wright, Jr., argued the cause for appellant (Hunt, Hamlin & Ridley, attorneys; Isaac Wright, Jr., on the briefs).

Paul H. Heinzel, Assistant Prosecutor, argued the cause for respondent (Michael H. Robertson, Somerset County Prosecutor, attorney; Paul H. Heinzel, of counsel and on the briefs).

JUSTICE SOLOMON delivered the opinion of the Court.

We granted defendant Isaiah Bell’s motion for leave to appeal to this

Court to consider whether the prosecutor’s failure to instruct the grand jury on

lesser-included offenses for murder in response to questions posed by a grand 1 juror constituted an abuse of prosecutorial discretion warranting dismissal of

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State v. Isaiah Bell (081743) (Somerset County & Statewide), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-isaiah-bell-081743-somerset-county-statewide-nj-2020.