State v. Yusef B. Allen

Supreme Court of New Jersey·Decided July 29, 2026·No. A-7-25·Published

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. Yusuf B. Allen (A-7-25) (090853)

Argued March 30, 2026 -- Decided July 29, 2026

JUSTICE WAINER APTER, writing for a unanimous Court.

In this appeal, the Court considers the proper measure of “materiality” for a claim that the State failed to turn over evidence under Brady v. Maryland, 373 U.S. 83 (1963), including whether the materiality standard articulated in State v. Carter, 86 N.J. 300 (1981) applies, and whether the record in this case meets that standard.

Defendant Yusef B. Allen was tried for the murder of Lannie Silver, Jr. At the trial, Ruby Waller testified that on October 15, 1997, she and Silver went to a house where she purchased crack cocaine. When Silver inquired about purchasing drugs, defendant and Ben McNeil exited the house and yelled, “get the F out of here, [we] don’t sell drugs [here], white mother-f*****.” Silver put his hands up and backed away. Defendant went back into the house and returned with a gun, at which point Waller ran to her house. Defendant and McNeil continued to yell at Silver. Waller heard a gunshot, ran inside, and heard “several more” gunshots and “the victim screaming.” She looked out the window and saw Silver fall to the ground, crawl to the middle of the street, and collapse. Waller anonymously called 911.

Waller testified that on October 27, after learning Silver had died, she contacted the Plainfield Police Department to give a formal statement. In that statement, she again identified defendant and McNeil as suspects and told police that she saw defendant holding a gun. Waller testified that she had three cocaine possession convictions from 1990 to 1991 and that she was arrested for shoplifting on June 21, 1998. Noting that the shoplifting case was ongoing, the prosecutor asked Waller whether she was expecting any benefit with respect to that case for her testimony in defendant’s case. She said that she was not and that she did not have any matters pending when she gave her October 27 statement.

Defendant was found guilty of murder and weapons offenses. His conviction was affirmed on direct appeal. 337 N.J. Super. 259, 264, 275 (App. Div. 2001). In the many years since, defendant has been challenging the jury verdict in direct and collateral appeals brought in State and federal courts.

1 In 2013, defendant sought habeas relief in federal court. Among other claims, defendant argued that the prosecutor violated Brady by failing to disclose Ruby Waller’s April 19, 1991 plea agreement, pursuant to which she had received three years’ imprisonment in exchange for testifying in the trial of her co-defendant. The federal court found defendant’s claim meritless; defendant then filed a motion for a new trial based on newly discovered evidence in state court, arguing that withholding the plea agreement violated Brady because the agreement “could have been used for impeachment . . . of the [S]tate’s chief witness.”

Following an initial denial of the motion, reversed by the Appellate Division, assigned counsel for defendant filed a motion for a “new trial based upon newly discovered evidence” under Carter, 85 N.J. at 313. The motion court denied defendant’s motion. The Appellate Division affirmed in part and remanded in part. 482 N.J. Super. 142, 169 (App. Div. 2025). As relevant here, the appellate court concluded that the motion court erred in evaluating defendant’s claims under Carter, rather than Brady, but the error was harmless because “we see no practical difference between the materiality/harmless error elements set forth in the Brady and Carter formulations.” Id. at 164. The Court granted certification limited to the appropriate materiality standard and its application. 261 N.J. 605 (2025).

HELD: The Brady and Carter materiality standards are not the same. Defendant has not satisfied Brady materiality in this case, so the Court affirms as modified.

1. In Brady, the United States Supreme Court held “that the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment.” 373 U.S. at 87. The Court later expanded Brady to apply to impeachment evidence as well as exculpatory evidence known to police investigators or to prosecutors, even if defendant submits no request. There are thus three elements to a Brady claim: (1) The evidence at issue must be favorable to the accused, either because it is exculpatory, or because it is impeaching; (2) the evidence must have been suppressed by the State, either willfully or inadvertently; and (3) prejudice must have ensued. The third component, prejudice, is also known as the materiality requirement. Because the materiality inquiry lies at the center of this case, the Court reviews its evolution in depth. Brady itself did not set forth any test for materiality. In Strickland v. Washington, the Court elaborated on why the materiality standard that governed a motion for a new trial based on newly discovered evidence was inappropriate for Brady claims, and also for ineffective assistance of counsel claims. 466 U.S. 668, 694 (1984). Ultimately, the Court identified the materiality test for Brady purposes as requiring the petitioner to show “that there is a reasonable probability that his conviction or sentence would have been different had [the Brady] materials been disclosed.” Strickler v. Greene, 527 U.S. 263, 296 (1999). (pp. 16-22) 2 2. State v. Carter, on the other hand, addresses situations in which a defendant comes forward after trial with newly discovered evidence that did not come from the prosecution. 85 N.J. at 313. For a new trial to be granted under Carter, “the new evidence must be (1) material to the issue and not merely cumulative or impeaching or contradictory; (2) discovered since the trial and not discoverable by reasonable diligence beforehand; and (3) of the sort that would probably change the jury’s verdict if a new trial were granted.” Id. at 314 (emphasis added). That test “is more stringent” than the “Brady analysis.” Ibid. (p. 22)

3. Reviewing those standards closely, the Court finds that the Appellate Division erred in holding that the Brady and Carter materiality standards are the same. For Brady claims, the word “reasonable” modifies “probability” -- and a “reasonable probability” that the result of the proceeding would have been different does not require a defendant to show that the verdict more likely than not would have been different, or to demonstrate by a preponderance that the verdict would have been different. The widely used standard for assessing motions for a new trial based on newly discovered evidence, however, generally does require a showing that the new evidence “more likely than not” would, or “by a preponderance of the evidence” would, change the outcome of the case. Strickland, 466 U.S. at 693-94. When it comes to materiality, “probably” or “more likely than not” is a more demanding standard than “reasonable probability.” The Court clears up any confusion from cross quotations in past cases by holding today that “would probably change the jury’s verdict” is a more stringent standard than “a reasonable probability” that the jury’s verdict would change. (pp. 23-30)

4.

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