mistake of fact doctrine (New Jersey) · Go Syfert
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mistake of fact doctrine in New Jersey

6 New Jersey opinions name it 2 courts 1998–2021 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 (3)

CaseFollowedCited
Illinois v. Rodriguezgreen
scotus · 1990 · cited in 2 New Jersey opinions naming this issue, 2021–2021
2 sentences

2021The mistake of fact doctrine, the dissent explained, springs from the “recognition that police officers operating in the field have to make quick decisions.” Id. at 73 (citing Illinois v. Rodriguez, 497 U.S. 177, 186 (1990)).

2021The mistake of fact doctrine, the dissent explained, springs from the “recognition that police officers operating in the field have to make quick decisions.” Id. at 73 (citing Illinois v. Rodriguez, 497 U.S. 177, 186 (1990)).

22
United States v. Cortezgreen
scotus · 1981 · cited in 2 New Jersey opinions naming this issue, 2021–2021
2 sentences

2021The doctrine also stems from an “understanding that police officers have the expertise to ‘dra[w] inferences and mak[e] deductions . . . that might well elude an untrained person.’” Ibid. (alterations and omission in original) (quoting United States v. Cortez, 449 U.S. 411, 418 (1981)). 38 By contrast, Justice Sotomayor noted, “the meaning of the law is not probabilistic in the same way that factual determinations are.” Ibid.

2021The doctrine also stems from an “understanding that police officers have the expertise to ‘dra[w] inferences and mak[e] deductions . . . that might well elude an untrained person.’” Ibid. (alterations and omission in original) (quoting United States v. Cortez, 449 U.S. 411, 418 (1981)). 38 By contrast, Justice Sotomayor noted, “the meaning of the law is not probabilistic in the same way that factual determinations are.” Ibid.

22
State v. Warrengreen
nj · 1986 · cited in 1 New Jersey opinions naming this issue, 2004–2004
2 sentences

2004I fully appreciate that “erroneous [jury] instructions on material issues are presumed to be reversible error, excusable only if they are harmless beyond a reasonable doubt.” State v. Warren, 104 N.J. 571, 579 , 518 A.2d 218, 222 (1986) (internal citation and quotation marks omitted).

2004I fully appreciate that “erroneous [jury] instructions on material issues are presumed to be reversible error, excusable only if they are harmless beyond a reasonable doubt.” State v. Warren, 104 N.J. 571, 579 , 518 A.2d 218, 222 (1986) (internal citation and quotation marks omitted).

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 (2)

CaseCitedYears
Wilson v. Tard green
njd · 1984
2 sentences

1999The Appellate Division relied on Wilson v. Tard, 593 F.Supp. 1091 (D.N.J.1984), in which Judge Stern, applying New Jersey law, reversed a conviction of aggravated manslaughter because the trial court had charged the jury that defendant carried the burden of establishing his mistake-of-fact defense by a preponderance of the evidence.

1998Wilson v. Tard, supra, 593 F.Supp. at 1096 .] The State’s burden with respect to the mistake of fact defense to negate the reckless state of mind for a manslaughter conviction is no less compelling than the burden of disproving a reasonable perception of risk to justify a homicide.

21998–1999
State v. Drew green
njsuperctappdiv · 2006
1 sentence

2019When the issue relates to a mistake of fact defense, the jury needs to hear an explanation of "what is required for liability to be established." Id. at 197 .

12019–2019

Where else courts name it

TX 186 (1983–2026) CA 138 (1961–2026) NM 29 (1978–2026) IN 27 (1985–2020) NY 19 (1975–2020) GA 17 (1975–2026) IL 14 (1991–2025) HI 14 (2002–2026) MA 11 (1988–2023) MI 9 (2000–2026) PA 9 (2000–2025) UT 7 (2009–2026) NJ 6 (1998–2021) CO 6 (1992–2016) ID 5 (1990–2022) NC 5 (1997–2020) SD 5 (1984–2024) OH 4 (2004–2019) KS 4 (2010–2023) MD 4 (2002–2025) MO 4 (1958–2013) TN 3 (1995–2015) KY 3 (1994–2021) AZ 2 (2017–2018) ND 2 (1996–2002) WI 2 (1980–1987) IA 2 (1987–2015) NV 2 (2020–2026) DC 2 (1992–2014) RI 2 (1998–2000) WA 2 (1997–1997)

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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