deferential abuse of discretion standard in New Jersey

2022This Court “generally review[s] a trial court’s decision to dismiss an indictment under the deferential abuse of discretion standard,” but “[w]hen the decision to dismiss relies on a purely legal question,” such as the interpretation of a statute, the Court “review[s] that determination de novo.” State v. Twiggs, 233 N.J. 513, 532 (2018).

2021And, although the grand jury determines whether there is probable cause, the decision to prosecute and what charge to file or bring before a grand jury, generally rests entirely in the prosecutor's discretion. [ 241 N.J. 552 , 559-60 (2020) (internal citations omitted).] As an appellate court, we generally review "a trial court's decision to dismiss an indictment under the deferential abuse of discretion standard." State v. Twiggs, 233 N.J. 513, 532 (2018).

2024State v. Robinson, 217 N.J. 594, 603 (2014).

2024State v. Robinson, 217 N.J. 594, 603 (2014).

2022In other words, “an 5 We therefore need not consider in detail the later problematic exchange recounted above. 22 appellate court should not substitute its own judgment for that of the trial court unless ‘the trial court’s ruling was so wide of the mark that a manifest denial of justice resulted.’” State v. Singh, 245 N.J. 1 , 13 (2021) (internal quotation marks omitted) (quoting State v. Brown, 170 N.J. 138, 147 (2001)).

2021An appellate court may "not substitute [its] judgment for the trial court's unless its 'ruling "was so wide of the mark that a manifest denial of justice resulted."'" Ibid. (quoting State v. Brown, 170 N.J. 138, 147 (2001)).

2020In a nutshell, a court examining a grand jury record should determine whether, viewing the evidence and the rational inferences drawn from that evidence in the light most favorable to the State, a grand jury could reasonably believe that a crime occurred and that the defendant committed it. [State v. Feliciano, 224 N.J. 351, 380-81 (2016) (citations omitted).] "We generally review a trial court's decision to dismiss an indictment under the deferential abuse of discretion standard." State v. Twiggs, 233 N.J. 513, 532 (2018) (citing Hogan, 144 N.J. at 229 ).

2020An appellate court will generally review a trial judge's decision on a motion to dismiss an indictment "under the deferential abuse of discretion standard." State v. Twiggs, 233 N.J. 513, 532 (2018) (citing State v. Hogan, 144 N.J. 216, 229 (1996)).

2022Evidentiary decisions are therefore reviewed by appellate courts under the deferential abuse of discretion standard, Hanges, 202 N.J. at 383-84 , and “we do not set such rulings aside unless it appears that ‘there has been a clear error of judgment,’” State v. Prall, 231 N.J. 567, 580 (2018) (quoting State v. J.A.C., 210 N.J. 281, 295 (2012)).

2022Evidentiary decisions are therefore reviewed by appellate courts under the deferential abuse of discretion standard, Hanges, 202 N.J. at 383-84 , and “we do not set such rulings aside unless it appears that ‘there has been a clear error of judgment,’” State v. Prall, 231 N.J. 567, 580 (2018) (quoting State v. J.A.C., 210 N.J. 281, 295 (2012)).

2022State v. Fuentes, 217 N.J. 57, 70 (2014).

2022See State v. Dabas, 215 N.J. 114 , 140–41 (2013) (finding that the trial court abused its discretion by not giving an adverse inference charge that defendant requested).

2021When considering the trial court's evidentiary rulings, we employ a deferential abuse of discretion standard, reviewing the rulings "only for a 'clear error in judgment.'" State v. Medina, 242 N.J. 397 , 412 (2020) (quoting State v. Scott, 229 N.J. 469, 479 (2017)).

2021An appellate court may "not substitute [its] judgment for the trial court's unless its 'ruling "was so wide of the mark that a manifest denial of justice resulted."'" Ibid. (quoting State v. Brown, 170 N.J. 138, 147 (2001)).

2020However, where, [as here,] the judge's decision involves "a purely legal question, . . . we review that determination de novo." Ibid. (citing State v. Cagno, 211 N.J. 488, 505-06 (2012)).

2020State v. Sainz, 107 N.J. 283, 292 (1987); State v. Roth, 95 N.J. 334, 364-65 (1984).

2020In a nutshell, a court examining a grand jury record should determine whether, viewing the evidence and the rational inferences drawn from that evidence in the light most favorable to the State, a grand jury could reasonably believe that a crime occurred and that the defendant committed it. [State v. Feliciano, 224 N.J. 351, 380-81 (2016) (citations omitted).] "We generally review a trial court's decision to dismiss an indictment under the deferential abuse of discretion standard." State v. Twiggs, 233 N.J. 513, 532 (2018) (citing Hogan, 144 N.J. at 229 ).

2020See Scharf, 225 N.J. at 572 (reiterating the well-settled principle that appellate courts generally review evidentiary rulings under a deferential abuse of discretion standard).

2020State v. Sainz, 107 N.J. 283, 292 (1987); State v. Roth, 95 N.J. 334, 364-65 (1984).