State of New Jersey, Plaintiff-Respondent v. James E. Zola, Defendant-Appellant

Summary

The Court affirmed the defendant’s murder conviction and the other non‑capital convictions, but reversed the death sentence and remanded for a new penalty‑phase trial because the jury instruction failed to require proof beyond a reasonable doubt that the statutory aggravating factors outweigh mitigating factors. The Court found no reversible error in the guilt‑phase trial, including voir dire, death‑qualification, the diminished‑capacity charge, the amylase expert testimony, and other issues. The Court directed the lower court to follow its prior Biegenwald and Ramseur standards on capital sentencing. Justice Handler, in a concurrence in part and dissent in part, would also reverse the aggravated sexual assault conviction.