State of New Jersey, Plaintiff-Respondent v. Diara Barden, Defendant-Appellant

Summary

The Supreme Court of New Jersey reversed the Appellate Division and remanded for a new trial, holding that the trial court erred in admitting evidence of the defendant’s prior drug sales as other‑crimes evidence or under a res gestae theory because the probative value was outweighed by prejudice and the limiting instruction was insufficient. The Court applied the Cofield test, found the evidence unduly prejudicial, and concluded it should have been excluded. Justice Albin, concurring, urged the Court to abandon the discredited doctrine of res gestae as an independent basis for admission of evidence.