State of New Jersey, Plaintiff-Respondent v. Ellen Gartland, Defendant-Appellant

Summary

The Supreme Court of New Jersey held that the appeal was not moot despite the defendant's death, that the trial court correctly instructed the jury on the statutory duty to retreat because the bedroom was not a separate dwelling, and that the jury instruction, taken as a whole, was sufficient to allow consideration of the defendant's prior abuse in assessing self‑defense. Accordingly, the Court reversed the Appellate Division and set aside the manslaughter conviction.