Supreme Court of New Jersey

State of New Jersey, Plaintiff-Respondent v. Steven Raymond Davis, Defendant-Appellant

August 3, 1989116 N.J. 341

Summary

The Supreme Court of New Jersey vacated the death sentence of Steven Raymond Davis and remanded for a new penalty‑phase trial because the jury charge failed to require a finding beyond a reasonable doubt that the statutory aggravating factors outweigh the mitigating factors. The Court also held that the Strickland standard for ineffective assistance of counsel applies equally in capital cases and that Davis’s guilty plea did not establish death‑eligibility under the Gerald rule, so a new guilt‑phase trial is required if the plea is not capital. The decision affirms the Court’s prior capital‑sentencing jurisprudence and orders further proceedings consistent with those standards.