State of New Jersey, Plaintiff-Appellant v. Carole Long, Defendant-Respondent

Summary

The Supreme Court of New Jersey held that the defendant's statements to the victim, as reported by the victim to her mother, are admissible under the state‑of‑mind (res gestae) exception and, where appropriate, the excited‑utterance exception to the hearsay rule. The Court rejected the lower courts' exclusion of the statements as other‑crime evidence and found that a Rule 403 balancing did not require exclusion. The judgment of the Appellate Division was reversed and the case was remanded for trial. Justice STEIN, dissenting in part, agreed with the admissibility under the state‑of‑mind exception but criticized the use of the term “res gestae” and the excited‑utterance analysis; Chief Justice PORITZ, in a separate concurrence, endorsed admission under both exceptions while noting the scholarly disapproval of the res gestae label.