State of New Jersey, Plaintiff-Appellant v. Braynard Purnell, Defendant-Respondent

Summary

The Supreme Court of New Jersey reversed the Appellate Division and held that the Anderson rule requiring a jury to decide the materiality element of perjury does not apply retroactively to post‑conviction relief petitions, and that under both New Jersey and federal (Teague) retroactivity standards the error is not structural, so the perjury conviction stands. Justice O’Hern dissented, arguing for retroactive application and reversal of the conviction.