Reversal of Manslaughter Conviction After Jury Accesses Taped Statement
- December 12, 2014
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Matthew Craddock was convicted of first-degree aggravated manslaughter (N.J.S.A. 2C:11-4(a)(1)), as a lesser included offense of murder charges, for the stabbing death of James Grace, who was dating Craddock’s ex-girlfriend, M.P. He was also convicted of third-degree possession of a weapon for an unlawful purpose (N.J.S.A. 2C:39-4(d)) and fourth-degree unlawful possession of a weapon (N.J.S.A. 2C:39-5(d)). At trial, in addition to other evidence presented, the jury heard the defendant’s entire taped confession to the police as well as a voicemail the defendant left on his girlfriend’s phone after the incident. Testimony for the State was also provided by M.P., her friend L.A., and L.A.’s fiance’ Mi.P who all witnessed the altercation between Craddock and Grace. None actually witnessed the actual stabbing but they did hear Grace yell “he stabbed me” and one saw the defendant throw an object that appeared to be a knife handle into the road. The defendant offered a different version of the facts than the others and claimed his actions were in self-defense as an altercation erupted when he was attempting to retrieve M.P.’s cell phone from another individual, Grace, who the defendant believed had stolen the phone. Craddock was sentenced to an aggregate 24-year term with an eighty-five percent parole ineligibility period under the No Early Release Act (NERA)(N.J.S.A. 2C:43-7.2). Craddock appealed based on the admission of the taped statements without redaction under claim that certain information in the recordings was more prejudicial than probative. In State v. Craddock, the NJ Appellate Division considered the holding in State v. Burr, 195 N.J. 119 (2008) wherein it was determined that allowing a jury full access to a videotaped statement had the potential for great prejudice. In State v. Miller, 205 N.J. 109 (2011) the court held that the review, by the jury, of taped statements should be undertaken in court where parties are present and judges my provide jury instructions with regard to portions replayed. Finally, in State v. A.R., 213 N.J. 542 (2013) the court held that the jury should not have unfettered access to audio or videotaped statements during deliberations. Once the appellate division determined that the trial court erred in providing the jury with unfettered access to the taped statements, it was further determined that the potential prejudice to the defendant from the jury’s access to the statements was not harmless error and the conviction was reversed with the matter remanded to the trial court for a new trial. If you are facing charges of murder, manslaughter or weapons charges, you are facing severe penalties including as much as life in prison. When confronting criminal charges, it is imperative that you have experienced criminal defense counsel at your side to ensure you are afforded due process and your rights are protected. For more information about murder, manslaughter, weapons offenses or other serious crimes in New Jersey visit HeatherDarlingLawyer.com. This blog is for informational purposes only and not intended to replace the advice of an attorney.