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

Summary

The New Jersey Supreme Court held that a trial court must apply a less stringent similarity standard when a defendant seeks to introduce other‑crimes evidence for exculpatory purposes and must balance its probative value against Rule 4 concerns. The Court remanded for the trial judge to determine admissibility on a factual basis and to order a new trial if the evidence is admitted, or to uphold the conviction if it is excluded.