State v. Reldan
167 N.J. Super. 595, 401 A.2d 563 (1979)
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Rule of Law:
A defendant is not entitled to a severance of charges for similar offenses if the evidence of one crime would be admissible in a separate trial of the other to prove a relevant issue, such as the identity of the perpetrator. The potential for prejudice from a joint trial is negated when the evidence of the crimes is mutually admissible under an exception to the prohibition on introducing evidence of other crimes.
Facts:
- On October 6, 1975, Susan Heynes was reported missing from her home in Haworth, New Jersey.
- On October 14, 1975, Susan Reeves was reported missing from her home in Demarest, New Jersey, a nearby town.
- On October 27, 1975, Susan Heynes's nude body was found in Rockland County, New York.
- The next day, October 28, 1975, Susan Reeves's nude body was found in a different park, also in Rockland County, New York.
- Both victims were women in their twenties of similar height and weight.
- A medical examiner determined that both victims died from strangulation caused by a ligature of pantyhose found around their necks.
- Both strangulations resulted in fractured hyoid bones, an injury the medical examiner stated occurred in less than 1% of strangulation cases.
- The medical examiner concluded that, in his opinion, the same person murdered both victims.
Procedural Posture:
- The State of New Jersey charged Robert Reldan with two counts of first-degree murder in a single indictment (S-63-77).
- The defendant, Reldan, filed a motion in the Superior Court of New Jersey, Law Division (a trial court), to sever the two counts and order separate trials pursuant to R. 3:15-2(b).
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Issue:
Does the joinder of two separate but similar murder charges in a single indictment create undue prejudice that requires the court to sever the charges for separate trials, where the evidence of each crime may be admissible in the trial of the other to prove identity?
Opinions:
Majority - Madden, J.S.C.
No. The joinder of two separate but similar murder charges does not create undue prejudice requiring severance when the evidence of each crime would be mutually admissible in separate trials. The court found that the evidence of one murder would be admissible in the trial of the other under Evidence Rule 55 to prove the identity of the perpetrator. This exception applies because the similarities between the two crimes were so unusual and distinctive as to create a signature, marking them as the work of a single individual. The key similarities included the victims' profiles, the disposal of the bodies, and particularly the unique modus operandi: strangulation by a pantyhose ligature resulting in a fractured hyoid bone. Since the evidence would be admissible even in separate trials, trying the charges together does not introduce any additional prejudice that would warrant severance. The court also rejected the defendant's other claims of prejudice, finding he had not made a convincing showing that he needed to testify on one count but not the other, and expressing confidence that a jury could be properly instructed to consider each count separately without improperly cumulating the evidence.
Analysis:
This case clarifies the standard for severing charges that are of the same or similar character. It demonstrates that the general rule against admitting 'other crimes' evidence is not a barrier to joinder if that evidence falls under a key exception, such as proving identity through a unique modus operandi. The decision establishes that the analysis of prejudice from joinder is directly linked to the evidentiary rules; if the evidence is mutually admissible, the primary basis for claiming prejudice is eliminated. This provides a strong basis for prosecutors to join offenses with a distinct 'signature,' streamlining judicial resources while still being considered fair to the defendant, because the same damaging evidence would be presented in separate trials anyway.
