New Jersey Statutes
N.J. Stat. § 2C:28-4 (2026)
False reports to law enforcement authorities
✓ current as of May 2026
2C:28-4. a. Falsely incriminating another. A person who knowingly gives or causes to be given false information to any law enforcement officer with purpose to implicate another commits a crime of the third degree, except the offense is a crime of the second degree if the false information which the actor gave or caused to be given would implicate the person in a crime of the first or second degree.
For the purposes of this subsection, knowledge of the grade of the crime about which the defendant gave false information is not an element of the offense and it shall not be a defense that the defendant did not know of the grade of the crime. b. Fictitious reports. A person commits a crime of the fourth degree if he:
(1) Reports or causes to be reported to law enforcement authorities an offense or other incident within their concern knowing that it did not occur; or
(2) Pretends to furnish or causes to be furnished such authorities with information relating to an offense or incident when he knows he has no information relating to such offense or incident.
Notes of Decisions
Cited in 25
cases (14 in the last 5 years), 1988–2026 · leading case: State of New Jersey v. L.S., 132 A.3d 938 (N.J. Super. Ct. App. Div. 2016).
State of New Jersey v. L.S., 132 A.3d 938 (N.J. Super. Ct. App. Div. 2016). “A person who knowingly gives or causes to be given false information to any law enforcement officer with purpose to implicate another commits a crime of the fourth degree.”
Johnson v. State, 542 A.2d 429 (Md. Ct. Spec. App. 1988). “, N.J. Stat. Ann. § 2C:28-4 (West 1982); 18 Pa.”
State v. Cameron Albarelli, 2016 VT 119, 159 A.3d 627 (Vt. 2016). “, N.J.S.A. 2C:28-4 (“A person who knowingly gives .”
Eugene Ruocchio Robert A. D'Angiolillo v. United Transp. Union, Local 60 Donald J. Bogen (Dan) United Transp. Union, 181 F.3d 376 (3d Cir. 1999). “§ 2C:28-3 (unsworn falsification to authorities); N.J. Stat. Ann. § 2C:28-4 (false reports to law enforcement authorities).”
Livingston v. City of Englewood New Jersey (D.N.J. 2025). “Similarly, Plaintiff cannot maintain his claim for N.J. Stat. Ann. § 2C:28-4(a)5, a state criminal statute, because he does not have standing to assert such a claim.”
State of New Jersey Vs. Neil Raciti (16-05-0951, Middlesex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “4 A-3070-17T1 Thereafter, defendant was indicted on one count of fourth-degree falsely incriminating another, N.J.S.A. 2C:28-4(a)3, and four counts of fourth-degree unsworn falsification to authorities, N.”
Paul D. Lancaster v. New Jersey Transit Corp. (N.J. Super. Ct. App. Div. 2025). “In count three, he alleged harassment and retaliation by defendant Andre Coleman, a regional supervisor, in violation of the LAD, N.J.S.A. 2C:28-4, N.J.S.A. 2C:30-2, N.J.S.”
El v. Atl. City freeholders/Bd. of Commissioners (D.N.J. 2023). “False reports to law enforcement agencies, N.J.S.A. § 2C:28-4 is also a criminal offense that does not create a private cause of action against a police officer for alleged false statements in an arrest report.”
R.J.B. v. M.R.G. (N.J. Super. Ct. App. Div. 2026). “2C:33-4(c),4 and false reporting under N.J.S.A. 2C:28-4(b).5 [or she]: (1) [t]akes or detains a minor child with the purpose of concealing the minor child and thereby depriving the child's other parent of custody or parenting time with the minor child[.”
Daniel Chirino Vs. City of Hoboken (l-3671-14, Hudson Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “of the criminal offense of filing a false police report, N.J.S.A. 2C:28-4. He noted that plaintiff involved other HPD officers in his accusations.”
State of New Jersey Vs. Ewart M. Guillette (11-02-0188, Union Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “2C:24-4(a) (counts six and seven); fourth-degree false reports to law enforcement authorities, N.J.S.A. 2C:28-4 (count eight); and fourth-degree contempt, N.”
State of New Jersey Vs. Joseph Tolotti (17-10-0909, Cumberland Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “1(a)(2) (count two); fourth-degree false reports to law enforcement, N.J.S.A. 2C:28-4(b)(1) (count three); fourth-degree tampering with evidence, N.”
N.J. Stat. § 2C:28-4(a): 9 cases
State of New Jersey v. L.S., 132 A.3d 938 (N.J. Super. Ct. App. Div. 2016). “A person who knowingly gives or causes to be given false information to any law enforcement officer with purpose to implicate another commits a crime of the fourth degree.”
Livingston v. City of Englewood New Jersey (D.N.J. 2025). “Similarly, Plaintiff cannot maintain his claim for N.J. Stat. Ann. § 2C:28-4(a)5, a state criminal statute, because he does not have standing to assert such a claim.”
State of New Jersey Vs. Neil Raciti (16-05-0951, Middlesex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “4 A-3070-17T1 Thereafter, defendant was indicted on one count of fourth-degree falsely incriminating another, N.J.S.A. 2C:28-4(a)3, and four counts of fourth-degree unsworn falsification to authorities, N.”
State of New Jersey Vs. Enoc Pimentel (15-06-0517, Passaic Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019).
State of New Jersey Vs. Kevin a. Vauters (12-05-0795 & 13-01-0029, Middlesex Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2021).
N.J. Stat. § 2C:28-4(b): 2 cases
State of New Jersey v. L.S., 132 A.3d 938 (N.J. Super. Ct. App. Div. 2016). “A person who knowingly gives or causes to be given false information to any law enforcement officer with purpose to implicate another commits a crime of the fourth degree.”
R.J.B. v. M.R.G. (N.J. Super. Ct. App. Div. 2026). “2C:33-4(c),4 and false reporting under N.J.S.A. 2C:28-4(b).5 [or she]: (1) [t]akes or detains a minor child with the purpose of concealing the minor child and thereby depriving the child's other parent of custody or parenting time with the minor child[.”
N.J. Stat. § 2C:28-4(b)(1): 5 cases
State of New Jersey v. L.S., 132 A.3d 938 (N.J. Super. Ct. App. Div. 2016). “A person who knowingly gives or causes to be given false information to any law enforcement officer with purpose to implicate another commits a crime of the fourth degree.”
State of New Jersey Vs. Joseph Tolotti (17-10-0909, Cumberland Cnty. & Statewide) (N.J. Super. Ct. App. Div. 2019). “1(a)(2) (count two); fourth-degree false reports to law enforcement, N.J.S.A. 2C:28-4(b)(1) (count three); fourth-degree tampering with evidence, N.”
State of New Jersey Vs. Rasheem W. Mcqueen & Myshira T. Allen-brewer (19-02-0302, Middlesex Cnty. & Statewide) (Consol.) (N.J. Super. Ct. App. Div. 2020).
State of New Jersey Vs. Eddie Gonzalez (17-01-0269 & 17-01-0271, Essex Cnty. & Statewide) (record Impounded) (Consol.) (N.J. Super. Ct. App. Div. 2020).
State of New Jersey v. E.G. (N.J. Super. Ct. App. Div. 2025).
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