Supreme Court of New Jersey

State of New Jersey, Plaintiff-Appellant v. Carl J. Garrison, Defendant-Respondent

March 20, 2017228 N.J. 182

Summary

The Supreme Court of New Jersey held that evidence of a strip‑poker game played by the defendant with the minor victims was admissible under N.J.R.E. 404(b) after satisfying the four‑part Cofield test, and that the trial court's limiting instruction was adequate. The Court also found the expert witness's statistical comment harmless under a plain‑error standard. Accordingly, the Court reversed the Appellate Division and reinstated the defendant's convictions, remanding for sentencing considerations.