State of New Jersey, Plaintiff-Respondent v. Raymond F. Garfole, Defendant-Appellant

Summary

The Supreme Court of New Jersey held that other‑crimes evidence offered by a defendant for exculpatory purposes is admissible if it is simply relevant to guilt or innocence, a lower standard than the high similarity requirement of Evid. R.55, and remanded the case for the trial court to apply a Evid. R.4 balancing test. Justice Pashman and Justice Sullivan dissented, arguing respectively that the remand renders the right to exculpatory evidence illusory and that the evidence should be excluded because the risk of confusion outweighs its relevance.