State of New Jersey, Plaintiff-Respondent v. Anderson Garron, Defendant-Appellant

Summary

The Supreme Court of New Jersey held that the trial court erred in excluding the victim’s prior conduct evidence under the Rape Shield Statute and reversed the convictions, remanding for a new trial with instructions on lesser‑included offenses. The Court reasoned that the excluded evidence was highly material to the consent defense and that the probative value substantially outweighed any prejudice. The Court also required the trial court to charge the lesser‑included offenses of sexual assault and sexual contact. Justice Coleman dissented, arguing that the evidence should remain excluded and that the majority’s approach undermines the Rape Shield Law.