State v. Isaiah J. Knight

CourtSupreme Court of New Jersey
DecidedMarch 5, 2024
DocketA-39-22
StatusPublished

This text of State v. Isaiah J. Knight (State v. Isaiah J. Knight) 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 J. Knight, (N.J. 2024).

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 and may not summarize all portions of the opinion.

State v. Isaiah J. Knight (A-39-22) (087822)

Argued October 10, 2023 -- Decided March 5, 2024

PIERRE-LOUIS, J., writing for a unanimous Court.

In this appeal, the Court considers whether, pursuant to New Jersey discovery rules, the State can obtain from defense counsel an affidavit that constitutes physical evidence of a crime.

On June 1, 2021, Tyzier White was fatally shot as he stood outside of the Neptune Lounge, a bar in Newark. Two men, known by their nicknames as “Zay” and “DJ Neptune,” witnessed the shooting. Both men provided sworn statements in which they identified the shooter, and both later selected defendant Isaiah Knight’s photograph from a photo array. On June 16, law enforcement arrested defendant.

On December 21, 2021, Zay gave a statement to law enforcement, claiming that a woman he met online took him to a residence in Newark. At some point after arriving at the residence and spending time with the woman, three individuals, including two masked men armed with guns, entered the room where Zay was. Zay stated that he was given a written affidavit and told to copy it. The affidavit recanted Zay’s original statement to law enforcement identifying defendant as the shooter. After Zay copied the recanting affidavit, the captors released him. Defendant’s sister and cousin were identified as two of the perpetrators and charged with witness tampering. A superseding indictment also charged defendant with second-degree conspiracy to commit witness tampering and two counts of second- degree kidnapping.

On April 4, 2022, the State filed a motion to compel discovery of the document Zay was allegedly forced to write, believing that defendant’s alleged co- conspirators turned it over to his counsel. The State’s certification in support of its motion to compel further alleged that DJ Neptune may have been forced to transcribe a similar recantation and that defense counsel might possess that document as well. The trial court granted the State’s motion to compel discovery, and the Appellate Division affirmed the trial court’s order. The Court granted leave to appeal. 253 N.J. 546 (2023).

1 HELD: The sought-after affidavit is physical evidence of the crimes of witness tampering and kidnapping for which defendant and others have been charged. It is therefore subject to reciprocal discovery under Rule 3:3-13(b)(2)(B) and (D).

1. Rule 3:13-3 codifies New Jersey’s open-file approach to pretrial discovery in criminal matters post-indictment. Although a defendant has a right to automatic and broad discovery of the evidence the State has gathered in support of its charges upon the issuance of an indictment, the Rule also places the onus on defense counsel to supply the prosecution with broad categories of items. This is often referred to as the “reciprocal discovery” rule or process. Under Rule 3:13-3(b)(2)(B) and (D), respectively, a defendant must provide the State with materials including “any relevant books, papers, [or] documents, including “writings,” that are “within the possession, custody or control of defense counsel,” as well as with “written statements, if any, . . . made by any witnesses whom the State may call as a witness at trial.” Significantly, the Rule “does not require discovery of a party’s work product consisting of internal reports, memoranda or documents made by that party or the party’s attorney or agents, in connection with the investigation, prosecution or defense of the matter.” R. 3:13-3(d) (emphases added). (pp. 13-15)

2. Beyond the Rule’s own exception, constitutional guarantees may bar compelling disclosure of certain materials in certain situations. The right against self- incrimination applies when the accused is compelled to make a testimonial communication that is incriminating. However, both the state and Fifth Amendment privileges against self-incrimination are personal to the defendant and cannot be asserted by or on behalf of third parties. The Sixth Amendment to the United States Constitution and Article I, Paragraph 10 of the New Jersey Constitution ensure the criminally accused the right to effective assistance of counsel, which includes the right to a thorough defense investigation. In State v. Mingo, the Court held that defense counsel cannot be compelled, via discovery, to give the State inculpatory expert materials it generated in preparation for trial unless the defense intends to introduce or use that expert evidence at trial, noting that such a rule furthers the right to effective assistance of counsel because defense counsel will not be deterred from “seek[ing] out expert evidence” to aid its defense that may turn out to be unfavorable. 77 N.J. 576, 582, 584 (1978). And one year after the Mingo decision, the Court expanded its holding to include statements or summaries of statements made by a State witness to defense counsel when the defense does not intend to use the statements at trial. State v. Williams, 80 N.J. 472, 480-82 (1979). The Court noted that “[i]t is abhorrent to our concept of criminal justice to compel a defendant, under the guise of reciprocal discovery, to disclose to the State inculpatory evidence uncovered by defense counsel during his preparation for trial and then allow the State to use that evidence as part of its case in chief.” Id. at 479. (pp. 15-21)

2 3. In this matter, neither party disputes that defense counsel played no role whatsoever in the genesis of Zay’s affidavit. The affidavit’s creation was allegedly the result of a kidnapping and witness intimidation plot for which defendant and two other individuals have been criminally charged. The affidavit, therefore, is physical evidence of a crime and does not fall within the exception to the discovery obligations set forth in Rule 3:13-3(d). Rather, the affidavit is a relevant writing potentially in defense counsel’s possession pursuant to Rule 3:13-3(b)(2)(B). The affidavit would also fall under Rule 3:13-3(b)(2)(D) as a written statement by a witness that the State intends to call at trial. Compelling defense counsel to turn over in discovery an item in his possession that is physical evidence of a crime does not trigger the same Sixth Amendment concerns found in Williams and Mingo. Further, because the discovery request here is directed to counsel, not defendant, and pertains to materials allegedly provided by others, defendant’s Fifth Amendment right -- a right personal to defendant that cannot be asserted by or on behalf of third parties -- is inapplicable here. The unique facts of this case lead to the conclusion that the affidavits, as physical evidence of a crime, fall within the discovery rules, and no constitutional privilege stands in the way of their production. The State can appropriately lay a foundation for the admission of the documents at trial by sanitizing the manner in which it came into possession of the documents without stating that the affidavits came from defense counsel. (pp. 21-24)

AFFIRMED and REMANDED to the trial court.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, SOLOMON, WAINER APTER, FASCIALE, and NORIEGA join in JUSTICE PIERRE- LOUIS’s opinion.

3 SUPREME COURT OF NEW JERSEY A-39 September Term 2022 087822

State of New Jersey,

Plaintiff-Respondent,

v.

Isaiah J. Knight,

Defendant-Appellant.

On appeal from the Superior Court, Appellate Division.

Argued Decided October 10, 2023 March 5, 2024

Brian P. Keenan, Assistant Deputy Public Defender, argued the cause for appellant (Joseph E. Krakora, Public Defender, attorney; Brian P. Keenan, of counsel and on the briefs).

Matthew E.

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Bluebook (online)
State v. Isaiah J. Knight, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-isaiah-j-knight-nj-2024.