indicated standard (New Jersey) · Go Syfert
← New Jersey issues

indicated standard in New Jersey

13 New Jersey opinions name it 2 courts 1959–2025 2 in the last five years

The cases below were cited by New Jersey courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
State v. Lee Funderburg (074760)green
nj · 2016 · cited in 2 New Jersey opinions naming this issue, 2018–2025
2 sentences

2025"Nor does the trial court have 'the obligation on its own meticulously to sift through the entire record . . . to see if some combination of facts and inferences might rationally sustain' a lesser charge like manslaughter." State v. Funderburg, 225 N.J. 66, 81 (2016) (quoting State v. Choice, 98 N.J. 295, 299 (1985)).

2018The clearly indicated standard requires a sua sponte instruction on a lesser-included offense "only where the facts in evidence 'clearly indicate' the appropriateness of the charge," ibid. (quoting State v. Savage, 172 N.J. 374, 397 (2002)), or where "there is 'obvious record support for such [a] charge[,]'" State v. Funderburg, 225 N.J. 66, 81 (2016) (quoting State v. Powell, 84 N.J. 305, 319 (1980)).

22
State v. Savagegreen
nj · 2002 · cited in 2 New Jersey opinions naming this issue, 2018–2021
2 sentences

2021The evidence "must 'jump[] off the page' to trigger a trial court's duty to sua sponte instruct a jury on that charge." Ibid. (alteration in original) (quoting State v. Denofa, 187 N.J. 24, 42 (2006)). "[J]ust because a charge meets the rational basis test does not mean it meets the clearly indicated standard." Id. at 145 .

2018The clearly indicated standard requires a sua sponte instruction on a lesser-included offense "only where the facts in evidence 'clearly indicate' the appropriateness of the charge," ibid. (quoting State v. Savage, 172 N.J. 374, 397 (2002)), or where "there is 'obvious record support for such [a] charge[,]'" State v. Funderburg, 225 N.J. 66, 81 (2016) (quoting State v. Powell, 84 N.J. 305, 319 (1980)).

12
State v. Sloanegreen
nj · 1988 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025A-1825-22 33 This clearly indicated standard does not require trial courts to "scour the statutes to determine if there are some uncharged offenses of which the defendant may be guilty." State v. Brent, 137 N.J. 107, 118 (1994) (quoting State v. Sloane, 111 N.J. 293, 302 (1988)).

11
State v. Choicegreen
nj · 1985 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025"Nor does the trial court have 'the obligation on its own meticulously to sift through the entire record . . . to see if some combination of facts and inferences might rationally sustain' a lesser charge like manslaughter." State v. Funderburg, 225 N.J. 66, 81 (2016) (quoting State v. Choice, 98 N.J. 295, 299 (1985)).

11
State v. Brentgreen
nj · 1994 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025A-1825-22 33 This clearly indicated standard does not require trial courts to "scour the statutes to determine if there are some uncharged offenses of which the defendant may be guilty." State v. Brent, 137 N.J. 107, 118 (1994) (quoting State v. Sloane, 111 N.J. 293, 302 (1988)).

11
State v. Denofagreen
nj · 2006 · cited in 1 New Jersey opinions naming this issue, 2021–2021
2 sentences

2021The evidence "must 'jump[] off the page' to trigger a trial court's duty to sua sponte instruct a jury on that charge." Ibid. (alteration in original) (quoting State v. Denofa, 187 N.J. 24, 42 (2006)). "[J]ust because a charge meets the rational basis test does not mean it meets the clearly indicated standard." Id. at 145 .

2021The evidence "must 'jump[] off the page' to trigger a trial court's duty to sua sponte instruct a jury on that charge." Ibid. (alteration in original) (quoting State v. Denofa, 187 N.J. 24, 42 (2006)). "[J]ust because a charge meets the rational basis test does not mean it meets the clearly indicated standard." Id. at 145 .

11
State v. Powellgreen
nj · 1980 · cited in 1 New Jersey opinions naming this issue, 2018–2018
1 sentence

2018The clearly indicated standard requires a sua sponte instruction on a lesser-included offense "only where the facts in evidence 'clearly indicate' the appropriateness of the charge," ibid. (quoting State v. Savage, 172 N.J. 374, 397 (2002)), or where "there is 'obvious record support for such [a] charge[,]'" State v. Funderburg, 225 N.J. 66, 81 (2016) (quoting State v. Powell, 84 N.J. 305, 319 (1980)).

11
State v. RTgreen
nj · 2011 · cited in 1 New Jersey opinions naming this issue, 2016–2016
2 sentences

2016Id. at 509, 16 A.3d 365 .

2016Id. at 509, 16 A.3d 365 .

11
Dwyer v. Ford Motor Co.green
nj · 1962 · cited in 1 New Jersey opinions naming this issue, 2004–2004
2 sentences

2004In Dwyer v. Ford Motor Co., 36 N.J. 487, 507 , 178 A. 2d 161, 171 (1962), the court indicated that the presumption of fact in the Dwyer case would be "... emptied of all probative force and disappears from the case upon the introduction of any proof to the contrary." Contrast the case of Spear v. Lyndale Mfg.

2004In Dwyer v. Ford Motor Co., 36 N.J. 487, 507 , 178 A. 2d 161, 171 (1962), the court indicated that the presumption of fact in the Dwyer case would be "... emptied of all probative force and disappears from the case upon the introduction of any proof to the contrary." Contrast the case of Spear v. Lyndale Mfg.

11
Meier v. Frank Mashuda Co.green
ohioctapp · 1959 · cited in 1 New Jersey opinions naming this issue, 1962–1962
1 sentence

1962Cf. Meier v. Frank Mashuda Company, - Ohio App. -, 168 N. E. 2d 319, 321 (1959).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
United States v. Lara green
scotus · 2004
2 sentences

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A. 2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed. 2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A.2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed.2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing s

22011–2011
Andrx Pharmaceuticals, Inc. v. Kroger Co. green
scotus · 2004
2 sentences

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A. 2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed. 2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A.2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed.2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing s

22011–2011
Crown Equipment Corp. v. McEuin green
scotus · 2004
2 sentences

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A. 2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed. 2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A.2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed.2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing s

22011–2011
State v. Garron green
nj · 2003
2 sentences

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A. 2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed. 2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing

2011Indeed, in State v. Garron, 177 N.J. 147 , 827 A. 2d 243 (2003), cert. denied, 540 U.S. 1160 , 124 S.Ct. 1169 , 157 L.Ed. 2d 1204 (2004), where we affirmed that the clearly indicated standard requires an instruction on a lesser-included offense, we took particular note of the fact that: in a case in which instructing a jury on a lesser-included offense would be so unanticipated by either party as to cause complete surprise, or so inconsistent with the defense as to undermine the fairness of the proceedings, the trial court may depart from this general rule, but must place its reasons for doing

22011–2011
State v. Alexander green
nj · 2018
1 sentence

2018The clearly indicated standard requires a sua sponte instruction on a lesser-included offense "only where the facts in evidence 'clearly indicate' the appropriateness of the charge," ibid. (quoting State v. Savage, 172 N.J. 374, 397 (2002)), or where "there is 'obvious record support for such [a] charge[,]'" State v. Funderburg, 225 N.J. 66, 81 (2016) (quoting State v. Powell, 84 N.J. 305, 319 (1980)).

12018–2018
Aluminum Co. v. Preferred Metal Products green
njd · 1965
2 sentences

2004Co., 35 N.J.Super. 385 , 114 A. 2d 314 (App.Div.1958) where the court indicated that the presumption at issue would disappear when met by "positive, substantial and repellent evidence." If the proof offered to refute the presumed evidential fact is equal to the supporting data of the elemental fact, then the opponent of the presumed evidential fact has failed to carry their burden of going forward, Aluminum Co. of America v. Preferred Metal Products, 37 F.R.D. 218 (D.N.J.1965).

2004Co., 35 N.J.Super. 385 , 114 A. 2d 314 (App.Div.1958) where the court indicated that the presumption at issue would disappear when met by "positive, substantial and repellent evidence." If the proof offered to refute the presumed evidential fact is equal to the supporting data of the elemental fact, then the opponent of the presumed evidential fact has failed to carry their burden of going forward, Aluminum Co. of America v. Preferred Metal Products, 37 F.R.D. 218 (D.N.J.1965).

12004–2004
Spear v. Lyndale Manufacturing Co. green
njsuperctappdiv · 1955
2 sentences

2004Co., 35 N.J.Super. 385 , 114 A. 2d 314 (App.Div.1958) where the court indicated that the presumption at issue would disappear when met by "positive, substantial and repellent evidence." If the proof offered to refute the presumed evidential fact is equal to the supporting data of the elemental fact, then the opponent of the presumed evidential fact has failed to carry their burden of going forward, Aluminum Co. of America v. Preferred Metal Products, 37 F.R.D. 218 (D.N.J.1965).

2004Co., 35 N.J.Super. 385 , 114 A. 2d 314 (App.Div.1958) where the court indicated that the presumption at issue would disappear when met by "positive, substantial and repellent evidence." If the proof offered to refute the presumed evidential fact is equal to the supporting data of the elemental fact, then the opponent of the presumed evidential fact has failed to carry their burden of going forward, Aluminum Co. of America v. Preferred Metal Products, 37 F.R.D. 218 (D.N.J.1965).

12004–2004
NCR Corp. v. South Carolina Department of Revenue & Taxation green
scotus · 1994
1 sentence

2003Ibid.

12003–2003
Hopkins v. Fox & Lazo Realtors green
nj · 1993
1 sentence

2000Ibid.

12000–2000
Cleveland Board of Education v. Loudermill green
scotus · 1985
2 sentences

1991In Loudermill the Court indicated that the hearing “though necessary, need not be elaborate.” 470 U.S. at 545 , 105 S.Ct. at 1495 , 84 L.Ed.2d at 506 . “[T]he formality and procedural requisites for the hearing can vary, depending upon the importance of the interests involved and the nature of the subsequent proceedings.” Id., quoting Boddie v. Connecticut, supra, 401 U.S. at 378 , 91 S.Ct. at 786 , 28 L.Ed.2d at 119 .

1991In Loudermill the Court indicated that the hearing “though necessary, need not be elaborate.” 470 U.S. at 545 , 105 S.Ct. at 1495 , 84 L.Ed.2d at 506 . “[T]he formality and procedural requisites for the hearing can vary, depending upon the importance of the interests involved and the nature of the subsequent proceedings.” Id., quoting Boddie v. Connecticut, supra, 401 U.S. at 378 , 91 S.Ct. at 786 , 28 L.Ed.2d at 119 .

11991–1991
Boddie v. Connecticut green
scotus · 1971
2 sentences

1991In Loudermill the Court indicated that the hearing “though necessary, need not be elaborate.” 470 U.S. at 545 , 105 S.Ct. at 1495 , 84 L.Ed.2d at 506 . “[T]he formality and procedural requisites for the hearing can vary, depending upon the importance of the interests involved and the nature of the subsequent proceedings.” Id., quoting Boddie v. Connecticut, supra, 401 U.S. at 378 , 91 S.Ct. at 786 , 28 L.Ed.2d at 119 .

1991In Loudermill the Court indicated that the hearing “though necessary, need not be elaborate.” 470 U.S. at 545 , 105 S.Ct. at 1495 , 84 L.Ed.2d at 506 . “[T]he formality and procedural requisites for the hearing can vary, depending upon the importance of the interests involved and the nature of the subsequent proceedings.” Id., quoting Boddie v. Connecticut, supra, 401 U.S. at 378 , 91 S.Ct. at 786 , 28 L.Ed.2d at 119 .

11991–1991
State v. Deatore green
nj · 1976
2 sentences

1988Regardless of the relevance of jury-bias as a viable test in civil cases, e.g., Wright v. Bernstein, supra, or in ordinary criminal cases, e.g., State v. Deatore, supra, it cannot serve as the standard in á capital case.

1988Regardless of the relevance of jury-bias as a viable test in civil cases, e.g., Wright v. Bernstein, supra , or in ordinary criminal cases, e.g., State v. Deatore, supra , it cannot serve as the standard in a capital case.

11988–1988
Wright v. Bernstein green
nj · 1957
2 sentences

1988Regardless of the relevance of jury-bias as a viable test in civil cases, e.g., Wright v. Bernstein, supra, or in ordinary criminal cases, e.g., State v. Deatore, supra, it cannot serve as the standard in á capital case.

1988Regardless of the relevance of jury-bias as a viable test in civil cases, e.g., Wright v. Bernstein, supra , or in ordinary criminal cases, e.g., State v. Deatore, supra , it cannot serve as the standard in a capital case.

11988–1988
Converse v. Portsmouth Cotton Oil Refining Corp. green
ca4 · 1922
1 sentence

1962The court indicated that this defense might be sound if the defendant’s work could not have been done without inflicting the injury; however, it then proceeded to find for the plaintiff, pointing out that the defendant could have used other dumping grounds which were available “subject only to approval of the officer in *419 charge.” 281 F., at p. 985 .

11962–1962
Fred v. Mayor and Council, Old Tappan Borough green
nj · 1952
1 sentence

1959(See Fred v. Mayor and Council, Old Tappan Borough, 10 N.J. 515 (1952).) In that light, there is much to commend judicial acquiescence in the construction of the statute and its administrative implementation by the New Brunswick authorities in the case before us.

11959–1959

Statutes the citing opinions construe

NJ § N.J. Stat. § 2C:11-3 (3) NJ § N.J. Stat. § 2C:39-4 (3) NJ § N.J. Stat. § 2C:39-5 (3) NJ § N.J. Stat. § 2C:43-7.2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 31 (1922–2024) CA 26 (1966–2024) MI 15 (1969–2023) IL 15 (1966–2007) NJ 13 (1959–2025) PA 12 (1963–2022) TX 11 (1914–2017) OR 10 (1963–2020) FL 9 (1966–2019) WA 8 (1954–2013) OH 7 (1998–2023) WV 7 (1973–2026) KS 7 (1905–2014) DC 6 (1984–2024) AL 5 (1910–2025) MO 5 (1961–2000) MD 4 (1985–1989) LA 4 (1969–1994) AZ 4 (1969–1990) VA 4 (1974–2013) IN 4 (1981–2015) CT 4 (1996–2008) WI 4 (1975–1997) NC 3 (1978–2004) VT 3 (1983–2023) ND 3 (1969–2006) IA 3 (1982–2022) MA 2 (1980–2000) ID 2 (2003–2012) NE 2 (2002–2004)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check