testimonial hearing (New Jersey) · Go Syfert
← New Jersey issues

testimonial hearing in New Jersey

51 New Jersey opinions name it 2 courts 1964–2026 24 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 (21)

CaseFollowedCited
State v. S.S.green
nj · 2017 · cited in 15 New Jersey opinions naming this issue, 2019–2026
2 sentences

2026After a testimonial hearing, we "defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to have the "feel" of the case, which a reviewing court cannot enjoy.'" State v. S.S., 229 N.J. 360, 374 (2017) (quoting State v. Elders, 192 N.J. 224, 244 (2007)); see also State v. Locurto, 157 N.J. 463, 474 (1999) ("Appellate courts should defer to trial courts' credibility findings that are often influenced by matters such as observations of the character and demeanor of witnesses and common human experience that are not transmitted by

2026After a testimonial hearing, "appellate courts defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to have the "feel" of the case, which a reviewing court cannot enjoy.'" State v. S.S., 229 N.J. 360, 374 (2017) (quoting State v. Elders, 192 N.J. 224 , 244 A-4138-24 11 (2007)).

1515
State v. Eldersgreen
nj · 2007 · cited in 14 New Jersey opinions naming this issue, 2018–2026
2 sentences

2026After a testimonial hearing, we "defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to have the "feel" of the case, which a reviewing court cannot enjoy.'" State v. S.S., 229 N.J. 360, 374 (2017) (quoting State v. Elders, 192 N.J. 224, 244 (2007)); see also State v. Locurto, 157 N.J. 463, 474 (1999) ("Appellate courts should defer to trial courts' credibility findings that are often influenced by matters such as observations of the character and demeanor of witnesses and common human experience that are not transmitted by

2026After a testimonial hearing, "appellate courts defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to have the "feel" of the case, which a reviewing court cannot enjoy.'" State v. S.S., 229 N.J. 360, 374 (2017) (quoting State v. Elders, 192 N.J. 224 , 244 A-4138-24 11 (2007)).

1214
State v. Locurtogreen
nj · 1999 · cited in 7 New Jersey opinions naming this issue, 2025–2026
2 sentences

2026After a testimonial hearing, we "defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to have the "feel" of the case, which a reviewing court cannot enjoy.'" State v. A-1867-24 10 S.S., 229 N.J. 360, 374 (2017) (quoting Elders, 192 N.J. at 244 ); see also State v. Locurto, 157 N.J. 463, 474 (1999) (recognizing deference is afforded because the court's findings "are often influenced by matters such as observations of the character and demeanor of witnesses and common human experience that are not transmitted by the record") (

2026After a testimonial hearing, we "defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to have the "feel" of the case, which a reviewing court cannot enjoy.'" State v. S.S., 229 N.J. 360, 374 (2017) (quoting State v. Elders, 192 N.J. 224, 244 (2007)); see also State v. Locurto, 157 N.J. 463, 474 (1999) ("Appellate courts should defer to trial courts' credibility findings that are often influenced by matters such as observations of the character and demeanor of witnesses and common human experience that are not transmitted by

77
State v. Johnsongreen
nj · 1964 · cited in 4 New Jersey opinions naming this issue, 2020–2024
2 sentences

2024State v. Johnson, 42 N.J. 146, 161 (1964); State v. S.S., 229 N.J. 360, 381 (2017).

2021Although the court's "'feel' of the case" and opportunity to assess credibility of live witnesses is a powerful reason to defer to findings made after a testimonial hearing, see State v. Johnson, 42 N.J. 146, 161 (1964), we defer to the trial court even when it bases its findings solely on its review of documentary or video evidence, State v. S.S., 229 N.J. 360, 381 (2017).

44
State v. Parkergreen
njsuperctappdiv · 2019 · cited in 3 New Jersey opinions naming this issue, 2020–2020
2 sentences

2020See R. 3:5-7(c) (mandating a testimonial suppression hearing when material facts are in dispute); State v. Parker, 459 N.J.

2020See R. 3:5-7(c) (mandating a testimonial suppression hearing when material facts are in dispute); State v. Parker, 459 N.J.

33
State v. Hewinsgreen
njsuperctappdiv · 1979 · cited in 3 New Jersey opinions naming this issue, 2024–2025
2 sentences

2025Super. 520 , 528 (App. Div. 2023) (second alteration in original) (quoting Hewins, 166 N.J.

2024Super. 318 , 332 (App. Div. 2021)). "'[F]actual allegations which are general and conclusory or based on suspicion and conjecture [do] not suffice' to establish a dispute of material facts warranting a testimonial hearing." Ibid. (alteration in original) (quoting State v. Hewins, 166 N.J.

23
State v. Terrell Hubbard (073539)green
nj · 2015 · cited in 2 New Jersey opinions naming this issue, 2020–2026
2 sentences

2026"A trial court's legal conclusions, 'however, and the consequences that flow from established facts,' are reviewed de novo." State v. Bullock, 253 N.J. 512 , 532 (2023) (quoting State v. Hubbard, 222 N.J. 249, 263 (2015)).

2020In reviewing a trial court's decision to admit or exclude a defendant's statement following a testimonial hearing, we "must defer to the factual findings of the trial court so long as those findings are supported by sufficient evidence in the record" and "disregard those findings" only when they "are clearly mistaken." State v. Hubbard, 222 N.J. 249, 262 (2015).

22
State v. Suazogreen
nj · 1993 · cited in 2 New Jersey opinions naming this issue, 2020–2020
2 sentences

2020See, e.g., State v. Lamb, 218 N.J. 300, 318 (2014); State v. Suazo, 133 N.J. 315, 320 (1993); Crumb, 307 N.J.

2020See, e.g., State v. Lamb, 218 N.J. 300, 318 (2014); State v. Suazo, 133 N.J. 315, 320 (1993); Crumb, 307 N.J.

22
State v. Robinsongreen
nj · 2009 · cited in 2 New Jersey opinions naming this issue, 2020–2020
2 sentences

2020State v. Robinson, 200 N.J. 1, 20 (2009).

2020State v. Robinson, 200 N.J. 1, 20 (2009).

22
State v. Michael Lamb (071262)green
nj · 2014 · cited in 2 New Jersey opinions naming this issue, 2020–2020
2 sentences

2020See, e.g., State v. Lamb, 218 N.J. 300, 318 (2014); State v. Suazo, 133 N.J. 315, 320 (1993); Crumb, 307 N.J.

2020See, e.g., State v. Lamb, 218 N.J. 300, 318 (2014); State v. Suazo, 133 N.J. 315, 320 (1993); Crumb, 307 N.J.

22
United States v. John Doe, Edmund J. Devlingreen
ca2 · 1968 · cited in 2 New Jersey opinions naming this issue, 1976–1976
2 sentences

1976“Even though evidence is not within a testimonial privilege, the due process clause protects against the use of excessive means to obtain it.” United States v. Doe, 405 F. 2d 436, 438 (2 Cir. 1968).

1976"Even though evidence is not within a testimonial privilege, the due process clause protects against the use of excessive means to obtain it." United States v. Doe, 405 F. 2d 436, 438 (2 Cir.1968).

22
State v. Mark Dunbar (077839) (Monmouth and Statewidegreen
nj · 2017 · cited in 2 New Jersey opinions naming this issue, 2022–2022
2 sentences

2022Accord State v. Dunbar, 229 N.J. 521, 538 (2017).

2022See Dunbar, 229 N.J. at 538 .

12
State v. Szemplered
nj · 1994 · cited in 2 New Jersey opinions naming this issue, 2000–2019
2 sentences

2000In Szemple, supra, 135 N.J. at 422-23 , 640 A. 2d 817 , the Supreme Court held that N.J.S.A. 2A:84A-23, as it then existed, conferred "a testimonial privilege only on clergypersons[,]" and the penitent had no power to preclude disclosure.

2000In Szemple, supra, 135 N.J. at 422-23 , 640 A. 2d 817 , the Supreme Court held that N.J.S.A. 2A:84A-23, as it then existed, conferred "a testimonial privilege only on clergypersons[,]" and the penitent had no power to preclude disclosure.

12
Stempler v. Speidellgreen
nj · 1985 · cited in 2 New Jersey opinions naming this issue, 1991–2003
2 sentences

2003Stempler, supra, 100 N.J. at 373 , 495 A. 2d at 859 .

2003Stempler, supra, 100 N.J. at 373 , 495 A. 2d at 859 .

12
State v. Nashgreen
nj · 2013 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025Super. 351, 373 (App. Div. 2014) (holding "where the court does not hold an evidentiary hearing, we may exercise de novo review over the factual inferences the trial court has drawn from the documentary record"); see also State v. Nash, 212 N.J. 518, 540-41 (2013) (recognizing appellate courts review any legal conclusions of the PCR court de novo).

11
State of New Jersey v. Alice O'Donnellgreen
njsuperctappdiv · 2014 · cited in 1 New Jersey opinions naming this issue, 2025–2025
1 sentence

2025See State v. Gideon, 244 N.J. 538 , 551 (2021) (recognizing an appellate court reviews a PCR order following a testimonial hearing for an abuse of discretion); State v. O'Donnell, 435 N.J.

11
State of New Jersey v. Horace Blakegreen
njsuperctappdiv · 2016 · cited in 1 New Jersey opinions naming this issue, 2021–2021
1 sentence

2021R. 2:11-3(e)(2); see State v. Blake, 444 N.J.

11
K.A.F. v. D.L.M.green
njsuperctappdiv · 2014 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020Turning to the need for a plenary hearing, it is beyond peradventure that a testimonial hearing is necessary when a genuine issue exists as to a material fact. "[A] plenary hearing is particularly important when the submissions show there is a genuine and substantial factual dispute regarding the welfare of children." K.A.F. v. D.L.M., 437 N.J.

11
Schneckloth v. Bustamontegreen
scotus · 1973 · cited in 1 New Jersey opinions naming this issue, 2020–2020
1 sentence

2020See Schneckloth v. Bustamonte, 412 U.S. 218, 227 (1974) (stating that voluntariness of consent is a factual issue).

11
Isaacson v. Isaacsongreen
njsuperctappdiv · 2002 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017Isaacson v. Isaacson, 348 N.J.

11
State v. Walkergreen
nj · 1979 · cited in 1 New Jersey opinions naming this issue, 1987–1987
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Hague v. Williamsgreen
nj · 1962 · cited in 1 New Jersey opinions naming this issue, 1991–1991
2 sentences

1991See generally Stempler v. Speidell, 100 N.J. 368, 374-383 , 495 A.2d 857 (1985) (discussing best method “to accord adequate recognition to the competing interests that have been identified”); Hague v. Williams, 37 N.J. 328, 336 , 181 A.2d 345 (1962) (stating that right of confidentiality is limited by “the supervening interest of society”).

1991See generally Stempler v. Speidell, 100 N.J. 368, 374-383 , 495 A.2d 857 (1985) (discussing best method “to accord adequate recognition to the competing interests that have been identified”); Hague v. Williams, 37 N.J. 328, 336 , 181 A.2d 345 (1962) (stating that right of confidentiality is limited by “the supervening interest of society”).

11

Also cited on this issue (21)

CaseCitedYears
Branzburg v. Hayes green
scotus · 1972
2 sentences

1978The United States Supreme Court in Branzburg v. Hayes, 408 U.S. 665 , 92 S.Ct. 2646 , 33 L.Ed. 2d 626 (1972), effectively so decided: * * * We are asked to create another [privilege] by interpreting the First Amendment to grant newsmen a testimonial privilege that other citizens do not enjoy.

1978The United States Supreme Court in Branzburg v. Hayes, 408 U.S. 665 , 92 S.Ct. 2646 , 33 L.Ed. 2d 626 (1972), effectively so decided: * * * We are asked to create another [privilege] by interpreting the First Amendment to grant newsmen a testimonial privilege that other citizens do not enjoy.

31972–1978
State v. Crumb green
njsuperctappdiv · 1997
2 sentences

2020See, e.g., State v. Lamb, 218 N.J. 300, 318 (2014); State v. Suazo, 133 N.J. 315, 320 (1993); Crumb, 307 N.J.

2020See, e.g., State v. Lamb, 218 N.J. 300, 318 (2014); State v. Suazo, 133 N.J. 315, 320 (1993); Crumb, 307 N.J.

22020–2020
State v. Kevin Gamble (071234) green
nj · 2014
2 sentences

2019After a testimonial hearing, "appellate courts defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to have the "feel" of the case, which a reviewing court cannot enjoy.'" Ibid. (quoting State v. Elders, 192 N.J. 224, 244 (2007)).

2018After a testimonial hearing, "appellate courts defer to the trial court's factual findings because the trial court has the 'opportunity to hear and see the witnesses and to A-2932-15T4 10 have the "feel" of the case, which a reviewing court cannot enjoy.'" Ibid. (quoting State v. Elders, 192 N.J. 224, 244 (2007)).

22018–2019
Miranda v. Arizona green
scotus · 1966
1 sentence

2026After conducting a testimonial hearing, the court 3 Miranda v. Arizona, 384 U.S. 436 (1966).

12026–2026
Terry v. Ohio green
scotus · 1968
1 sentence

2020Defendant's reply brief alleged that when police approached his van, they had "absolutely no probable cause or reasonable suspicion that a crime ha[d] taken place or was about to take place . . . and conducted an illegal warrantless search without any exception to the warrant requirement being present." As to the clear plastic bag containing 133 white glassine envelopes of heroin that was detected in defendant's waistband during the pat-down for possible weapons, defendant contended: "The feel of 133 smal[l] packets of heroin in no way g[a]ve rise to an honest belief that [defendant] was in po

12020–2020
Lewis v. Harris green
nj · 2006
2 sentences

2013Id. at 448-49 , 908 A.2d 196 .

2013Id. at 448-49 , 908 A.2d 196 .

12013–2013
Namet v. United States green
scotus · 1963
2 sentences

2007“First, some courts have indicated that error may be based upon a concept of prosecutorial misconduct, when the Government makes a conscious and flagrant attempt to build its case out of inferences arising from use of the testimonial privilege.” Id. at 186 , 83 S.Ct. at 1154-55 , 10 L.Ed.2d at 283 .

2007“First, some courts have indicated that error may be based upon a concept of prosecutorial misconduct, when the Government makes a conscious and flagrant attempt to build its case out of inferences arising from use of the testimonial privilege.” Id. at 186 , 83 S.Ct. at 1154-55 , 10 L.Ed.2d at 283 .

12007–2007
Matter of DK green
njsuperctappdiv · 1985
2 sentences

2005R. 4:86-7 (“the court shall ... take oral testimony in open court”); In re D.K., 204 N.J.Super. 205, 227 , 497 A.2d 1298 (Ch.Div.1985).

2005R. 4:86-7 (“the court shall ... take oral testimony in open court”); In re D.K., 204 N.J.Super. 205, 227 , 497 A.2d 1298 (Ch.Div.1985).

12005–2005
Rozycki v. Peley green
njsuperctappdiv · 1984
1 sentence

2002Ibid. (citing Evid.

12002–2002
Eaton v. Eaton neutral
nj · 1989
11990–1990
Frank v. Ivy Club neutral
nj · 1989
11990–1990
Nolan v. Lee Ho green
nj · 1990
11990–1990
In Re Bridge green
njsuperctappdiv · 1972
11978–1978
Zemel v. Rusk green
scotus · 1965
11978–1978
United States v. Liddy green
dcd · 1972
11978–1978
Pell v. Procunier green
scotus · 1974
11978–1978
Houchins v. KQED, Inc. green
scotus · 1978
11978–1978
Zurcher v. Stanford Daily green
scotus · 1978
11978–1978
Zemel v. Rusk green
scotus · 1965
11978–1978
State v. Jones green
· 1910
11978–1978
Reina v. United States green
scotus · 1960
11964–1964

Statutes the citing opinions construe

NJ § N.J. Stat. § 2C:44-1 (13) NJ § N.J. Stat. § 2C:43-7.2 (11) NJ § N.J. Stat. § 2C:35-5 (10) NJ § N.J. Stat. § 2C:39-5 (10) NJ § N.J. Stat. § 2C:39-4 (9) NJ § N.J. Stat. § 2C:35-10 (8) NJ § N.J. Stat. § 2C:5-2 (7) NJ § N.J. Stat. § 2C:11-3 (6) NJ § N.J. Stat. § 2C:39-7 (6) NJ § N.J. Stat. § 2C:39-3 (5) NJ § N.J. Stat. § 2C:12-1 (4) NJ § N.J. Stat. § 2C:35-7 (4)

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

OH 69 (1981–2026) NJ 51 (1964–2026) NY 46 (1955–2023) CA 38 (1959–2024) WA 37 (1967–2024) MI 31 (1960–2025) ME 24 (1973–2021) IL 23 (1980–2023) MD 21 (1983–2022) MA 21 (1972–2025) TX 20 (1968–2023) CT 16 (1974–2022) MN 15 (1968–2026) PA 15 (1980–2026) GA 14 (1978–2013) AL 14 (1903–2011) FL 13 (1908–2023) AZ 12 (1968–2019) MO 11 (1979–2024) CO 8 (1980–2021) IN 8 (1991–2015) NM 8 (1973–2022) WI 8 (1976–2008) NC 8 (1975–2022) RI 8 (1984–2019) TN 7 (2000–2010) ID 7 (1977–2026) VT 6 (1989–2016) AR 6 (1982–2021) OR 6 (1975–2024) DC 6 (1972–2014) WY 5 (1981–2019) SD 4 (1986–2025) SC 4 (1996–2014) KY 4 (1984–2019) NH 4 (1975–2005) OK 4 (1987–1991) LA 4 (1996–2025) NE 3 (1995–2021) AK 2 (1991–2018) KS 2 (1982–2017)

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