State v. Mathis
47 N.J. 455, 221 A.2d 529, 1966 N.J. LEXIS 233 (1966)
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Rule of Law:
A defendant has a right to cross-examine a prosecution witness regarding the specific nature of pending criminal charges against that witness to demonstrate potential bias, interest, or a motive to testify favorably for the State. Prohibiting such cross-examination constitutes reversible error.
Facts:
- Stanley Caswell, an insurance collector, was making his rounds on North Ninth Street in Kenilworth.
- Marvin Mathis was at the same location to visit his father.
- A witness, James Faines, saw Mathis pushing Caswell, who was bleeding and moaning, into the back of Caswell's car.
- Another witness, Lewis Clark, was with Faines and testified to a similar account, though he did not see the victim's face.
- Moments before, witnesses heard two reports resembling firecrackers.
- Caswell's car was later driven to a wooded area, where two more shots were fired and the car was set on fire.
- Caswell's charred body was found inside; an autopsy revealed he died from four .22 caliber gunshot wounds.
- Mathis fled to New York City but surrendered to the F.B.I. two days later.
Procedural Posture:
- Marvin Mathis was indicted for murder in the first degree.
- In response to a demand, the State provided a bill of particulars specifying its theory as a killing during an 'attempt to rob'.
- At a trial in the court of first instance, the State introduced evidence of a completed robbery, leading to a series of motions and rulings where the trial court ultimately struck the evidence of the completed robbery.
- The trial court sustained the State's objection to the defense's attempt to cross-examine witness Lewis Clark about the nature of four criminal charges pending against him.
- The trial court also permitted the prosecutor to cross-examine Mathis about his employment history and allowed rebuttal witnesses on the topic, despite an earlier ruling against exploring Mathis's financial need as a motive.
- The trial court did not instruct the jury on the lesser-included offense of second-degree murder.
- A jury convicted Mathis of murder in the first degree without a recommendation for life imprisonment, leading to a mandatory death sentence.
- Mathis filed a direct appeal of his conviction and sentence to the Supreme Court of New Jersey.
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Issue:
Did the trial court commit reversible error by prohibiting defense counsel from cross-examining a key prosecution witness about the nature of his pending criminal charges to show potential bias?
Opinions:
Majority - Weintraub, C.J.
Yes. It was reversible error to prohibit the defense from questioning a key witness about the nature of his pending criminal charges. A defendant is entitled to expose a witness's potential bias or hope of reward from the State, and the gravity of the pending charges is crucial for the jury to properly assess the witness's credibility. The trial court's refusal to permit this line of questioning was a critical error, as the witness's testimony was a damning part of the State's case. The court also found error in the prosecution's attempt to use Mathis's alleged financial need as a motive for the crime, reasoning that poverty alone is an impermissibly prejudicial basis to suggest a propensity to commit crime. Additionally, the court clarified for the purposes of retrial that under the felony-murder rule, a variance between a charge of 'attempted robbery' and proof of a 'completed robbery' is not fatal, because the core element is the felonious intent to rob, not its successful completion.
Analysis:
This decision reinforces a defendant's fundamental Sixth Amendment right to confront and cross-examine adverse witnesses, specifically clarifying that the scope of inquiry into witness bias includes the nature of pending charges. By deeming the preclusion of such questions reversible error, the court emphasized the importance of allowing the jury to fully evaluate a witness's potential motives for testifying. The opinion also provides significant guidance on felony-murder doctrine in New Jersey, holding that the legal distinction between an 'attempt' and a 'completed' felony does not create a fatal variance that would absolve a defendant. Lastly, it strongly reaffirms the evidentiary rule against using a defendant's general poverty as proof of motive, protecting indigent defendants from unfair prejudice.
