Supreme Court of New Jersey

State of New Jersey, Plaintiff-Appellant and Cross-Respondent v. James Calvin Hill, Defendant-Respondent and…

August 1, 1990121 N.J. 150

Summary

The Supreme Court of New Jersey affirmed the Appellate Division's decision and remanded for further proceedings. It held that fresh‑complaint statements must be spontaneous and not the product of coercive questioning, and that trial courts may, in their discretion, exclude cumulative fresh‑complaint testimony when it is prejudicial. The Court also directed the lower court to reassess the admissibility of the statements made to Ms. McCabe and Detective Hoffman.