State of New Jersey, Plaintiff-Respondent v. Naquan O’neil, A/K/A Naquan O’neal, Defendant-Appellant

Summary

The New Jersey Supreme Court granted the defendant’s post‑conviction relief petition, holding that his appellate counsel’s failure to raise the valid self‑defense argument for aggravated manslaughter and manslaughter constituted ineffective assistance of counsel. Because the error was prejudicial, the Court vacated the aggravated‑manslaughter conviction and remanded for a new trial. The decision also reaffirmed that self‑defense is a complete defense to reckless homicide offenses under the Code of Criminal Justice.