State v. Kanem Williamson (083979) (Essex County & Statewide)

CourtSupreme Court of New Jersey
DecidedMay 10, 2021
DocketA-65-19
StatusPublished

This text of State v. Kanem Williamson (083979) (Essex County & Statewide) (State v. Kanem Williamson (083979) (Essex 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. Kanem Williamson (083979) (Essex County & Statewide), (N.J. 2021).

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. Kanem Williamson (A-65-19) (083979)

Argued January 19, 2021 -- Decided May 10, 2021

SOLOMON, J., writing for the Court.

In this appeal, the Court considers (1) whether the trial court abused its discretion by admitting A.B.’s identification of defendant as a dying declaration; and (2) whether the admission of A.B.’s identification violated defendant’s right to confrontation.

On a spring afternoon in 2014, emergency services personnel responded to a shooting in front of a housing complex. Upon arrival, police found A.B. lying face down in a pool of blood on the steps outside the complex. Paramedics administered CPR and epinephrine to restart her heart, intubated A.B., and were able to revive her pulse. A.B. arrived at the hospital about twenty minutes later.

About two hours after being shot, A.B. regained consciousness but was unable to speak because of the breathing tube. A.B.’s attending physician, Dr. Anastasia Kunac, told A.B. that she had been shot several times, her heart had stopped and been restarted, and an injury to her spine left her a quadriplegic and unable to breathe on her own. Dr. Kunac also told A.B. that she could die. Upon learning the nature and severity of her condition, A.B. became visibly upset and started to cry.

Detective Filiberto Padilla arrived at the scene of the shooting. Following investigative leads, he and other officers spoke with Kanem Morris, defendant’s father, who told police that defendant had admitted to shooting A.B. and left shortly before police arrived. Officers took statements from Morris and another witness, who also implicated defendant in A.B.’s shooting.

Detective Padilla obtained defendant’s mugshot photograph and went to the hospital. He had a videotaped exchange with A.B., who could communicate only by nodding or shaking her head. Detective Padilla asked whether she knew who shot her; whether she knew where she was at that time; whether she had known the person who shot her for a while; whether the shooter was from the complex; whether the person in the photograph was the person who shot her; whether she had had any arguments with that person that day; and whether she was sure that was the person who shot her. A.B.

1 nodded in the affirmative to all of the questions except about having had an argument; in answer to that question, she shook her head in the negative.

A.B. died eleven months after the shooting. Defendant was indicted for the murder of A.B. and weapons offenses. Before trial, the State moved to admit into evidence, as a dying declaration under N.J.R.E. 804(b)(2), A.B.’s videotaped statement identifying defendant.

During an evidentiary hearing on the State’s motion, the trial court heard testimony from one of the paramedics who responded to the scene of A.B.’s shooting, Dr. Kunac, and Detective Padilla. The trial court found all three to be credible, stating they appeared “calm and composed” with “knowledge of the facts to which they testified.” The trial court also found that A.B. was “fully cognizant” of her injuries and “the possibility of her imminent death.” The trial court concluded that A.B.’s statement did not violate the Confrontation Clause and admitted the statement. After a trial, the jury convicted defendant of a lesser included offense of murder and of the weapons charges. The Appellate Division affirmed. The Court granted certification, limited to the two questions noted above. 241 N.J. 485, 485-86 (2020).

HELD: The trial court correctly admitted A.B.’s statement identifying defendant as her shooter as a dying declaration under N.J.R.E. 804(b)(2), and the admission of A.B.’s statement as a dying declaration does not violate the Confrontation Clause of the Sixth Amendment to the United States Constitution or Article I, Paragraph 10 of the New Jersey Constitution.

1. The dying declaration exception to the rule against hearsay is based on the belief that persons making such statements are highly unlikely to lie. New Jersey has codified the exception in N.J.R.E. 804(b)(2), which states that, “[i]n a criminal proceeding, a statement made by a victim unavailable as a witness is admissible if it was made voluntarily and in good faith and while the declarant believed in the imminence of declarant’s impending death.” “[B]elief of imminent death,” see State v. Prall, 231 N.J. 567, 585 (2018), requires “a settled hopeless expectation that death is near at hand, and what is said must have been spoken in the hush of its impending presence,” Shepard v. United States, 290 U.S. 96, 100 (1933). A dying declaration is no less reliable because the victim has survived. “Despair of recovery may . . . be gathered from the circumstances . . . .” Prall, 231 N.J. at 585. “What is decisive is the state of mind.” Shepard, 290 U.S. at 100. Determining the declarant’s state of mind at the time the statement is made requires consideration of all attendant circumstances. (pp. 17-20)

2. Here, A.B. had been shot five times and was unresponsive with no pulse at the scene of the shooting. When she awoke, A.B. could not speak because of a breathing tube. She learned she could not breathe on her own, her heart had stopped, she was a quadriplegic, and she could die. She remained in critical condition thereafter, which Dr. Kunac 2 described as “at imminent risk of death.” And A.B. cried after learning about her condition, demonstrating that she fully appreciated the gravity of her situation. None of the medications administered to A.B. would have impaired her mental state, and A.B.’s nods and head shakes were voluntary movements. Considering the totality of the circumstances in determining A.B.’s state of mind at the time of her statement, A.B.’s identification of defendant was made voluntarily, in good faith, and while she “believed in the imminence of [her own] impending death” with no hope of recovery. N.J.R.E. 804(b)(2); see also Prall, 231 N.J. at 585. The trial court did not abuse its discretion in admitting A.B.’s dying declaration identifying defendant. (pp. 20-22)

3. Article I, Paragraph 10 of the New Jersey Constitution and the Sixth Amendment to the United States Constitution both guarantee a criminal defendant’s right to be confronted with the witnesses against him. In Crawford v. Washington, the United States Supreme Court held that “[w]here testimonial evidence is at issue . . . the Sixth Amendment demands what the common law required: unavailability and a prior opportunity for cross-examination.” 541 U.S. 36, 68 (2004). The protections of the Confrontation Clause thus apply to all out-of-court statements that are “testimonial.” The Crawford Court intimated that the permissible exceptions to the right of confrontation would be “those . . . established at the time of the founding,” id. at 54, and noted the existence of the exception for dying declarations, id. at 56 n.6. The Crawford Court explained that, “[i]f this exception must be accepted on historical grounds, it is sui generis.” Id. at 56 n.6. The Court reviews post-Crawford cases in which the United States Supreme Court has raised, but not resolved, whether dying declarations are exceptions to the Confrontation Clause; those include Giles v. California, 554 U.S. 353 (2008), which reaffirmed founding-era common law exceptions to the right of confrontation.

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State v. Kanem Williamson (083979) (Essex County & Statewide), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kanem-williamson-083979-essex-county-statewide-nj-2021.