State v. John T. Bragg

CourtSupreme Court of New Jersey
DecidedMay 6, 2025
DocketA-13-24
StatusPublished

This text of State v. John T. Bragg (State v. John T. Bragg) 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. John T. Bragg, (N.J. 2025).

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. John T. Bragg (A-13-24) (089446)

Argued March 3, 2025 -- Decided May 6, 2025

RABNER, C.J., writing for a unanimous Court.

In this appeal, the Court considers whether it was plain error not to instruct the jury about the “castle doctrine,” a part of the law on self-defense. Under certain circumstances, individuals may use force against others to protect themselves. But they may not use deadly force if they can retreat with complete safety. The castle doctrine provides an exception to the duty to retreat: a person “is not obliged to retreat from his dwelling, unless he was the initial aggressor.” N.J.S.A. 2C:3-4(b)(2)(b)(i).

On the night of September 30, 2017, defendant John Bragg drove Lorenza Fletcher, her cousin Daquan Anderson, and her three-year-old son to an apartment complex in Trenton, where he signed in with a security guard in the lobby of the complex. The State points to that as evidence defendant was a guest, not a tenant. The group then went to an apartment on the ninth floor. According to all three adults, defendant had a key to enter the apartment. Inside it was an air mattress, a television, pots and pans, and some alcohol. Defendant testified that he had an informal sublease with the apartment’s tenant and had been staying there for “a few weeks” by the night in question.

At the apartment, a violent fight erupted. A neighbor eventually called the police. When the police arrived, all three adults required emergency medical care. The police arrested defendant and took him into custody. A grand jury later returned a nineteen-count indictment charging defendant with various offenses, including some, like attempted murder, for which self-defense may be asserted as a defense.

Defendant, Fletcher, and Anderson all testified at trial. Defendant claimed Fletcher and Anderson initiated the fight; they claimed defendant was the aggressor. Self-defense was a focal point of the trial. The State repeatedly questioned defendant about his claim of self-defense and highlighted that defendant did not retreat from the apartment in cross-examination and summation. The trial judge conducted two conferences about the proposed jury charge. The charge did not include guidance on the exception to the duty to retreat. The jury found defendant guilty of twelve counts in the indictment and of two lesser-included offenses. 1 The Appellate Division affirmed defendant’s convictions and sentence. The Court granted certification limited to the jury instruction regarding the duty to retreat. 258 N.J. 547 (2024).

HELD: Whether defendant should have retreated was a critical part of certain offenses charged in this case. Jurors heard the State press the point at trial; they also heard conflicting accounts of who the “initial aggressor” was and whether the apartment was defendant’s “dwelling.” But the jury received no direction as to how those disputed facts related to -- or had the potential to negate -- the duty to retreat in this case. Under the circumstances, the failure to give the jury guidance on the castle doctrine was clearly capable of producing an unjust result. It was therefore plain error not to instruct the jury on the issue.

1. Self-defense is an affirmative defense under the Criminal Code. The use of force against “another person is justifiable when the actor reasonably believes that such force is immediately necessary for the purpose of protecting himself against the use of unlawful force by such other person on the present occasion.” N.J.S.A. 2C:3-4(a). “The use of deadly force is not justifiable . . . unless the actor reasonably believes that such force is necessary to protect himself against death or serious bodily harm.” Id. at (b)(2). “[N]or is it justifiable if . . . [t]he actor knows that he can avoid the necessity of using such force with complete safety by retreating.” Id. at (b)(2)(b). The latter requirement is known as the duty to retreat. The Code contains an exception to the duty to retreat: “The actor is not obliged to retreat from his dwelling, unless he was the initial aggressor.” Id. at (b)(2)(b)(i). The Code defines “dwelling” broadly as “any building or structure, though movable or temporary, or a portion thereof, which is for the time being the actor’s home or place of lodging.” N.J.S.A. 2C:3-11(c) (emphases added). The definition encompasses an apartment and plainly extends beyond a permanent home. Whether an act of alleged self-defense took place in an individual’s “dwelling” is ordinarily a factual question for the jury, as is whether a defendant was the “initial aggressor.” (pp. 12-16)

2. The Model Jury Charge for self-defense includes language about the duty to retreat. It sets forth the duty in one sentence and, in a second sentence labeled “charge where applicable,” states that “[a]n exception to the rule of retreat, however, is that a person need not retreat from his or her own dwelling . . . unless he/she was the initial aggressor.” The Court asks the Committee on Model Criminal Jury Charges to add to the definition of “dwelling” by drawing from the text of N.J.S.A. 2C:3-11(c), but that does not affect its consideration of this appeal. Here, the trial court read to the jury the sentence about the duty to retreat but not the second sentence about the exception to that duty. The Court reviews in detail the discussions between the trial judge and counsel as the jury charges were prepared. Although the conversations are difficult to follow without access to the draft charges under discussion, counsel ultimately agreed with the court’s proposed charge and had no exceptions to the charge after it was read 2 to the jury. The Court thus reviews the failure to charge the jury on the exception to the duty to retreat for plain error -- error sufficient to raise a reasonable doubt as to whether it led the jury to a result it otherwise might not have reached. (pp. 16-22)

3. Here, both sides to the fight testified that they acted in self-defense. The State stressed the theme that defendant was obliged to retreat rather than use deadly force. The trial court instructed the jury on the duty to retreat but not about the exception to the duty to retreat. Whether the exception applied depended on two issues: Was defendant in his dwelling? And was he the initial aggressor? See N.J.S.A. 2C:3- 4(b)(2)(b)(i). “Dwelling” is broadly defined by statute, and evidence in the record supported defendant’s claim that the apartment was his dwelling. He testified that he had an informal sublease; other witnesses supported his claim that he lived in the apartment; and the police officers who responded confirmed there was an air mattress, clothing, cookware, and toiletries in the apartment. There was also disputed testimony about who the initial aggressor was. Each side accused the other of starting the fight, and each had injuries to support their claim. Both disputed factual issues were for the jury to decide. But the jury was not asked to resolve them. Nor did the jury receive any guidance about the significance of either issue or the overall exception to the duty to retreat. Without that information, the jury was clearly capable of finding that defendant was required to retreat rather than use deadly force. Yet a proper instruction was just as capable of leading jurors to conclude defendant had no such obligation and could stand his ground and defend himself if he was attacked. Under the circumstances here, the Court finds it was plain error not to instruct the jury on the exception to the duty to retreat. (pp. 22-25)

4.

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Bluebook (online)
State v. John T. Bragg, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-john-t-bragg-nj-2025.