flight instruction (New Jersey) · Go Syfert
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flight instruction in New Jersey

9 New Jersey opinions name it 2 courts 1992–2025 4 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 (11)

CaseFollowedCited
State v. Manngreen
nj · 1993 · cited in 4 New Jersey opinions naming this issue, 2020–2021
2 sentences

2021A flight instruction should be given when an unexplained departure "reasonably justif[ies] an inference that it was done with a consciousness of guilt and pursuant to an effort to avoid an accusation based on that guilt." State v. Mann, 132 N.J. 410, 418-19 (1993) (quoting State v. Sullivan, 43 N.J. 209, 238-39 (1964)).

2021State v. Mann, 132 N.J. 410, 420 (1993).

34
State v. Reddishgreen
nj · 2004 · cited in 2 New Jersey opinions naming this issue, 2020–2022
2 sentences

2022Again, we disagree. "[A]ppropriate and proper [jury] charges are essential for a fair trial." State v. Baum, 224 N.J. 147, 159 (2016) (quoting State v. Reddish, 181 N.J. 553, 613 (2004)).

2020Finally, "[a]s an indication of the paramount importance of accurate jury instructions, we have held that erroneous instructions on material issues are presumed to be reversible error." [State v. Reddish, 181 N.J. 553, 613 (2004) (alteration in original) (citation omitted) (quoting State v. Marshall, 173 N.J. 343, 359 (2002) (Marshall IV)).] The judge's flight instruction mirrored the Model Charge, according it a presumption of correctness.

22
State v. Longgreen
nj · 1990 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025See State v. Long, 119 N.J. 439, 499 (1990).

11
State v. Eugene C. Baum(073056)green
nj · 2016 · cited in 1 New Jersey opinions naming this issue, 2022–2022
1 sentence

2022Again, we disagree. "[A]ppropriate and proper [jury] charges are essential for a fair trial." State v. Baum, 224 N.J. 147, 159 (2016) (quoting State v. Reddish, 181 N.J. 553, 613 (2004)).

11
State v. Sullivangreen
nj · 1964 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021A flight instruction should be given when an unexplained departure "reasonably justif[ies] an inference that it was done with a consciousness of guilt and pursuant to an effort to avoid an accusation based on that guilt." State v. Mann, 132 N.J. 410, 418-19 (1993) (quoting State v. Sullivan, 43 N.J. 209, 238-39 (1964)).

11
United States v. Larry Allen Myersgreen
ca5 · 1977 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021The probative value of evidence related to flight depends upon the degree of confident with which four inferences can be drawn: (1) from the defendant's behavior to flight; (2) from flight to consciousness of guilt; (3) from consciousness of guilt to consciousness of guilt concerning the crime charged; and (4) from consciousness of guilt concerning the crime charge to actual guilt of the crime charged. [Id. at 420 (quoting United States v. Myers, 550 F.2d 1036, 1049 (1977).] Here, defense counsel objected to the flight charge.

11
Mogull v. CB Commercial Real Estate Group, Inc.green
nj · 2000 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020See State v. R.B., 183 N.J. 308, 325 (2005) (stating A-5387-17T4 21 trial court's obligation to deliver model charges); Mogull v. CB Comm. Real Estate Grp., Inc., 162 N.J. 449, 466 (2000) (noting "[i]t is difficult to find that a charge that follows the Model Charge so closely constitutes plain error").

11
State v. RBgreen
nj · 2005 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020See State v. R.B., 183 N.J. 308, 325 (2005) (stating A-5387-17T4 21 trial court's obligation to deliver model charges); Mogull v. CB Comm. Real Estate Grp., Inc., 162 N.J. 449, 466 (2000) (noting "[i]t is difficult to find that a charge that follows the Model Charge so closely constitutes plain error").

11
State v. Latneygreen
njsuperctappdiv · 2010 · cited in 1 New Jersey opinions naming this issue, 2020–2020
2 sentences

2020A flight instruction "is appropriate when there are 'circumstances present and unexplained which . . . reasonably justify an inference that it was done with a consciousness of guilt and pursuant to an effort to avoid an accusation based on that guilt.'" State v. Latney, 415 N.J.

2020Latney, 415 N.J.

11
State v. Marshallgreen
nj · 2002 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020Finally, "[a]s an indication of the paramount importance of accurate jury instructions, we have held that erroneous instructions on material issues are presumed to be reversible error." [State v. Reddish, 181 N.J. 553, 613 (2004) (alteration in original) (citation omitted) (quoting State v. Marshall, 173 N.J. 343, 359 (2002) (Marshall IV)).] The judge's flight instruction mirrored the Model Charge, according it a presumption of correctness.

11
State v. Wilsongreen
nj · 1970 · cited in 1 New Jersey opinions naming this issue, 2018–2018
1 sentence

2018The State argues that a flight instruction is appropriate when there are both plausible and sinister explanations for a defendant's flight, citing State v. Wilson, 57 N.J. 39, 48-49 (1970).

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 (1)

CaseCitedYears
State v. Melendez green
nj · 1992
1 sentence

1992The majority concludes, ante at 59, 609 A. 2d at 6 , that Fortuna's flight combined with the flight instruction cannot be characterized as evidence "against" Melendez for Confrontation Clause purposes because the trial court gave a limiting instruction.

11992–1992

Statutes the citing opinions construe

NJ § N.J. Stat. § 2C:43-7.2 (6) NJ § N.J. Stat. § 2C:44-1 (5) NJ § N.J. Stat. § 2C:11-3 (4) NJ § N.J. Stat. § 2C:12-1 (4) NJ § N.J. Stat. § 2C:39-5 (4) NJ § N.J. Stat. § 2C:39-7 (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

CA 196 (1951–2026) MS 82 (1984–2026) OH 74 (2003–2026) TN 51 (1985–2026) AZ 51 (1968–2024) FL 46 (1983–2014) NC 33 (1986–2026) OK 31 (1975–2026) PA 24 (1946–2023) NV 23 (1970–2025) MD 20 (2006–2026) MI 19 (2009–2025) IN 18 (1979–2014) CO 12 (1976–2026) IA 12 (1967–2016) UT 11 (1983–2021) RI 9 (1984–2009) NJ 9 (1992–2025) VA 8 (1993–2026) DC 8 (1980–2017) OR 7 (1977–1978) MT 6 (1999–2021) SD 6 (1975–2009) CT 6 (1989–2018) MO 5 (1925–1975) DE 5 (1983–2025) IL 5 (1966–1979) AL 4 (1998–2023) GA 4 (1991–2020) LA 4 (1998–2013) WY 3 (2000–2016) WA 2 (1974–2024) KS 2 (1979–2004) VT 2 (2020–2023) ID 2 (2014–2022) NY 2 (1987–1995) TX 2 (1986–1995) AK 2 (1967–1996) ME 2 (2018–2018) MA 2 (2010–2026)

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.

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